Strengthening the EU’s Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) Framework
The European Commission’s Action Plan on AML/CFT aims to address regulatory fragmentation, promote effective enforcement, and strengthen the EU’s AML/CFT framework. The plan proposes several key measures to achieve these goals.
Proposed Measures
The Commission’s plan includes the following proposals:
Enhanced Supervision
- Establishing an integrated AML/CFT supervisor at EU level with direct powers over certain designated entities.
- Extending the European Banking Authority’s (EBA) role or establishing a new entity dedicated to AML/CFT supervision across all economic sectors.
Improved Cooperation and Intelligence Sharing
- Enhancing cooperation between Financial Intelligence Units (FIUs), including replacing Europol as the operator/host of FIU.net 2020.
- Improving joint analysis of suspicious transactions to enhance the effectiveness of AML/CFT efforts.
Public/Private Partnerships and Implementation
- Improving public/private partnerships in making better use of financial intelligence.
- Ensuring effective transposition and implementation of existing AML/CFT directives.
- Launching infringement proceedings against member states for failing to transpose 5AMLD.
- Monitoring the establishment by member states of public registers of beneficial ownership.
International Cooperation
- Playing a more prominent role in setting international standards in AML/CFT rules, including representing the EU at the Financial Action Task Force (FATF).
Considerations and Challenges
While the Commission’s approach is welcomed, some elements deserve careful consideration:
- Transforming key AML/CFT provisions into an EU regulation may not achieve its intended aim of strengthening compliance due to disparate national legal and regulatory systems.
- The ever-evolving schemes put in place by criminals/terrorists to transfer funds may render the EU regulation insufficiently flexible and dynamic.
- Any reform of EU AML/CFT rules must fully respect the principles of independence and self-regulation of the legal profession.
Conclusion
The Commission’s Action Plan aims to strengthen the EU’s AML/CFT framework, promote effective enforcement, and address regulatory fragmentation. While some elements require careful consideration, the plan represents a significant step towards enhancing the EU’s ability to combat money laundering and terrorist financing.