This publication presents recommendations on how to build a more
effective anti-money laundering/combating the financing of terrorism
(AML/CFT) ecosystem across Europe. Our recommendations aim to better
implement the existing AML/CFT legislation. This aligns with the
European Commission (EC) intentions for its upcoming proposals: to
ensure that the current legislative environment works effectively.
To this end, we propose upgrading the role of: i) non-financial
obliged entities – including accountants – ii) supervisors and policy
makers. Some of our key recommendations are:
- obliged entities need to:
- change from reactive to proactive AML risk management
- integrate AML into their governance
- supervisors and policy makers should promote cooperation between Member States and between the public and private sector