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EBIC has some concerns about the proposed new definition of serious offences. A very wide range of minor offences will be included in the scope of money laundering predicate offences. This would run in contradiction with the risk-based approach introduced by the Directive.
EBIC welcomes the introduction of a risk based approach in the Directive. However, EBIC strongly recommends not to enter into too many details of the risk based approach, as the notion of risks is in constant evolution and specific to each bank and situation.