The AML package was published by the European Commission in 2021. Besides the establishment of an EU-wide AML authority, the package shall create a coherent legislative framework (‘single rulebook’) to improve the fight against money laundering and terrorist financing.

Notably, a first ever AML Regulation shall ensure a coherent set of rules for the private sector, including banks. One and a half years later, the discussions in the European Parliament are coming to an end and the final text will be discussed in trilogue meetings later this year.

To equip negotiators with background information on the banks’ concerns, the European Banking Industry Committee (EBIC) sent, on 7 February 2023, some main considerations to policy makers. The paper highlights selected priority issues of particular concern shared by the wider European banking sector, such as the exchange of information (both between group members of obliged entities and, in certain cases, private entities that operate within networks) and the measures to be taken regarding politically exposed persons.

The letter signed by the newly elected EBIC President Peter Simon also pointed to the importance of outsourcing possibilities, especially regarding the reporting of suspicious activities or threshold-based declarations to highly specialised service providers and elaborates on major concerns in the context of beneficial ownership.

In addition to other important messages, the EBIC stressed to disagree with reducing the percentage threshold serving as an indication of ownership of a legal entity from 25% to 5%, as suggested by some members of the European Parliament.

Read the full letter

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