In December 2022, the European Banking Authority (EBA) published draft Guidelines on the effective management of money laundering and terrorist financing (ML/TF) risks when providing access to financial services, accompanied by a revision of the non-profit organisation (NPO) provisions in the ML/TF risk factor Guidelines.

This new set of rules shall ensure that customers, especially the most vulnerable ones, are not denied access to financial services without a valid reason.

In response to the respective public consultation, ESBG submitted a position paper to the EBA on 3 February, highlighting some main observations on the definition of ML/TF risk, the situation where a client has been reported for suspicion of ML/TF as well as national jurisdictions that do not provide for accepting alternative identification documents.

Moreover, we stressed that payment and electronic money institutions should be covered by the Guidelines, to avoid loopholes in the system. The Guidelines are expected to be finalised by Q2 2023 and Q4 2023.