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