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EU Anti-Money Laundering Regulation Simplifies Supervision
The European Union’s new Anti-Money Laundering Regulation (AMLR) has simplified the supervision of anti-money laundering activities, eliminating the need for a transposition law. The AMLR serves as a “single rulebook” for all financial institutions, providing a uniform framework for oversight.
Risk-Based Approach
The AMLR’s risk-based approach is a significant implication of the new regulation. While Dutch financial institutions have made efforts to adopt a risk-based approach in recent years, the AMLR takes a different stance. For instance, while the De Nederlandsche Bank (DNB) recommends updating client data upon relevant changes or doubts about its correctness, the AMLR requires periodic updates every five years.
Harmonising AML Rules
The introduction of the AMLA and AMLR has harmonized anti-money laundering rules and supervision across the EU. This may reduce regulatory uncertainty for financial institutions, but it remains to be seen if the risk-based approach will prevail. The success of the new regulation depends on the focus of authorities on enhancing effectiveness rather than adding technical compliance.
Benefits and Challenges
The AMLR’s harmonization could bring benefits such as reduced regulatory uncertainty and a more effective fight against financial crime. However, implementing the new regulation may also pose challenges for financial institutions, particularly in terms of adapting to the risk-based approach and ensuring compliance with periodic update requirements.
Expert Insights
Marit Hoegen, Director at Deloitte Netherlands, notes that “the promise of the EU AML package lies in the hands of those working with the rules. If implemented correctly, it could lead to a more effective fight against financial crime.” Maarten Rijssenbeek, Partner at Deloitte Netherlands, adds that “the risk-based approach is crucial for success. Financial institutions must ensure they are tailoring their measures to specific risks and not just adding layers of technical compliance.”
Contact
For more information or to discuss the implications of the AMLR on your organization, please contact:
- Marit Hoegen, Director, Deloitte Netherlands: marithoegen@deloitte.nl
- Maarten Rijssenbeek, Partner, Deloitte Netherlands: mrijssenbeek@deloitte.nl
About NextGen AML
NextGen AML is a thought leadership platform that provides insights and expertise on anti-money laundering and financial crime compliance. Our mission is to empower organizations in their fight against financial crime, leveraging technology and innovation to create a more connected, impactful, and sustainable future.