Updated: October 2019
Cooperation between national supervisors and regulators
As stated above, ESBG opposes the establishing of an EU FIU in the future, as we believe it would just
duplicate the work national authorities already do.
Cooperation between supervisors and the private sector
Finally, we suggest that the next steps on the regulation of AML and CTF should focus on boosting the
dialogue between supervisors and private sector stakeholders, as the main flaws in AML and CTF
mechanisms are caused by a lack of cooperation and communication between the market operators and
the supervisory authority.
ESBG fully supports preventing money laundering and curbing terrorist financing.
However, we observe, that due to a surge in diverse phenomena related to the activities of financial
institutions, there is a clear need for a new approach on AML/CTF by EU institutions. We consider
that novel issues arising from the use of new technologies in financial services require a proper
regulation under a new approach.
For instance, we observe the following phenomena and drivers:
The EU tackled money laundering and terrorism financing with several instruments over the years.
Here we refer to the most recent initiatives adopted on these topics.
5th Anti-Money Laundering Directive
The 5th Anti-Money Laundering Directive amends the 4th Anti-Money Laundering Directive.
These amendments introduce substantial improvement to better equip the Union to prevent the financial
system from being used for money laundering and for funding terrorist activities.
Specifically, they will: