The EACB appreciates the opportunity extended by the European Commission to provide feedback on the update of its Supra-National Risk Assessment (SNRA).
The SRNAs are of crucial importance for cooperative banks because its outcomes are used as input for their Systemic Integrity Risk Assessment, and more generally, to assess the ML/TF risks associated with activities/services of supervised entities, which drives their AML/CTF risk acceptance criteria.
EACB’s comments on the 2022 SNRA focused on the following:
- The content and methodology for assessing risks, as well as the structure of the SNRA.
- The necessity to reflect recent developments in ML/TF threats and vulnerabilities, such as the risk associated with financial sanction enforcement, the misuses of legal entities and arrangements as non-profit organisations for ML/TF purposes, and threats linked to innovative financing solutions.
- The scope of obliged entities and the importance to focus on those recently included in the AML framework, as they may require additional attention in identifying and mitigating AML risks.
- The need to better incorporate the advancements around the beneficial ownership registers.
- The importance to highlight the information position of gatekeepers and, which reflects the urge for a better information sharing system.
Download the EACB comments to learn about cooperative banks’ position and our specific recommendations.