EPIF is delighted to share with you its response to the Commission AML Package.

EPIF very much welcomes the Commission’s proposals as part of the AML package. We have been strong supporters of moving to greater harmonization in the EU Anti-Money Laundering (AML) framework and we very much welcome the fact that parts of the Directives have been turned into a maximum harmonization Regulation.

EPIF welcomes greater harmonisation on several areas such as:

• Reduce reporting burden by streamlining technology and the data elements, as well as standardizing the reporting framework. EPIF welcomes the clearer rules on how reportable transactions are to be identified. EPIF looks forward to the AMLA draft implementing technical standards specifying a common template for the reporting of suspicious transactions to be used as a uniform basis throughout the EU. Having a more effective functioning of the FIUs’ analytical activities and cooperation is key to ensure the efficiency of the system.
• Clarifications and additional details regarding CDD. EPIF also supports building and implementing harmonising CDD procedures and a move from paper-based Know-Your-Customer (KYC) to online and innovative on-boarding and KYC solutions building on e-ID are key for EPIF members.
• Provisions clarifying the conditions that apply to the processing of certain categories of personal data of a more sensitive nature by obliged entities. EPIF has been calling for clarifications to create legal certainty around the application of the GDPR.