The European Association of Co-operative Banks welcomes the AML package proposal put forward by the European Commission. The package reflects the demand for a more efficient and harmonised EU AML framework. We also welcome the suggestion to create a centralised EU AML authority, the AMLA.
However, co-operative banks request that more work is done through level 1 legislation as currently the package lacks many concrete specifications, but authorises the AMLA or the Commission to issue RTS. The package should specify the essential obligations to allow practicable implementation and harmonised application.
Secondly, the package leaves the Member States a lot of room for manoeuvre. We request a more harmonised approach to have a truly harmonised EU framework.
Thirdly, to ensure a truly effective AML framework, also non-financial entities should be in the scope of the AML authorities.
Data exchange between public and private sectors and between private sector operators is essential to combat money laundering. However, the proposals for the AMLR and the new AML Directive insufficiently address data exchange between obliged entities. We believe the possibility for further harmonisation should be explored with regard to KYC and beneficial owners registers.
Further, in view of increasingly complex AML requirements, it is of crucial importance especially for small and medium-sized credit institutions to be able to outsource the range of tasks or individual aspects thereof as comprehensively as possible to highly specialised and reliable service providers.
Lastly, the new regulation and subsequent RTS on parameters and criteria for AML transaction monitoring should lead to a harmonised approach for transaction monitoring. This should serve as a basis for a EU central authority to take over the monitoring of EU-wide transactions. This would increase efficiency and effectiveness of AML transaction monitoring.
Please see our position papers on the proposals on AMLR, AMLA Regulation and AMLD6 for more details.