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EFAMA is particularly pleased with the Council’s acknowledgement that sector specificities need to be duly considered. EFAMA fully welcomes and supports the Council’s suggestion to require the prior consent of ESMA for any decision affecting financial market participants falling within its mandate.
As seen in recent AML cases, money-laundering risks are high in the banking space. An enhanced role for a better resourced EBA is therefore justified. That said, the scope of EU AML legislation goes well beyond the activities of credit institutions and captures other financial services activities as well.
It is thus important to ensure that future EU AML supervision work takes full account of the specificities of the various sectors in scope and that the relevant expertise is made available to that end.