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This Opinion will contribute to the European Commission's risk assessment work as well as that of the European Supervisory Authorities (EBA, EIOPA and ESMA - ESAs) of fostering supervisory convergence and a level playing field in the area of anti-money laundering (AML) and countering the financing of terrorism (CFT).
The Opinion also highlights difficulties associated with the lack of timely access to intelligence that might help firms identify and prevent terrorist financing, and considerable differences in the way national competent authorities discharge their functions.
These issues, if not addressed, risk diminishing the robustness of the EU's AML/CFT defences and more action is needed to ensure their effectiveness. This is particularly important as Member States move towards a more risk-based AML/CFT regime that requires a level of money laundering (ML) and terrorist financing (TF) risk awareness and management expertise, which not all firms and all sectors currently have.
Several initiatives are already underway, for example the ESAs' work on a common approach to risk-based AML/CFT supervision that, in the short to medium term, will serve to address many of the risks identified.