On 26 August the Institute of International Finance (IIF) provided feedback to the European Commission on its Action Plan for a comprehensive Union policy on preventing money laundering and terrorist financing, published in May 2020.

The IIF notes that a more coordinated approach to implement and oversea the EU’s anti-money laundering (AML) and counter terrorism financing (CTF) framework is imperative. In particular, the IIF considers that there are 3 key considerations for the European Commission to keep in mind:

  1. Greater consistency in the AML/CTF frameworks of the EU Member States, driven through implementation of the Financial Action Task Force (FATF) guidance
  2. Enhancements to information sharing within the EU, partnerships between private and public companies, reforms with regards to SARs and beneficial ownership, and better use of technology; and
  3. Complementing the work conducted by the FATF to ensure the operating effectiveness of global AML/CTF standards

The IIF indicates that a focus on these 3 key elements, augmented with the harmonization of requirements across the EU and application of a risk-based approach to supervision, will support the international effort to combat financial crime.