The European Banking Industry Committee (EBIC) considers that the current proposal of the Money Laundering Directive must be improved on several points. The two most important issues concern the definition of the beneficial owner and of politically exposed persons.
The definition of 'beneficial owner' should foresee a principle instead of too concrete rules. Should the EU nevertheless decide to opt for a detailed and concrete definition, credit institutions will not be able to meet those requirements as they do not have access to public registers to obtain the identity and to verify the identity of shareholders in non-listed companies and other legal arrangements.
The definition of Politically Exposed Persons runs in contradiction with the risk-based approach.
This definition should only cover persons:
from third countries
having prominent public functions at state level (i.e. high ranking PEPs)
having substantial or complex financial or business transactions which may represent enhanced money laundering and reputational risk
and persons identified as close family members and associates
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