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Harmonization of Anti-Money Laundering (AML) rules and supervision will facilitate a more effective
response to the challenges in the fight against money laundering. This will also ensure a level playing
field in the AML rules implementation among the member states.
In our feedback, we underline the need to maintain in the EU AML framework: i) the risk-based
approach and ii) the principle of proportionality. Risks can differ from country to country but also
amongst obliged entities and thus need tailored mitigation measures. In the AML ecosystem, all actors
need to collaborate and improve coordination amongst them. However, each actor has a different role
to play and different risks to encounter. And for that, we invite the European Commission (EC) to take
into consideration those differences in the proposed legislation, especially when it comes to its
implementation.
We also refer to a number of differences between the non-financial and financial obliged entities. These
differences are linked to their different roles in the market, the ways they operate but also to the risks
they encounter. Going ahead, we would like to see AMLA (Anti-Money Laundering Authority)
considering these differences in its decisions, while making sure that the respective roles and
responsibilities of oversight remain clear and distinct.
It will be key to ensure that the EC proposals are workable and can be implemented effectively. To this
end, we refer below (see Annex) to some areas that in our view require clarifications. We would like to
emphasise that the profession is welcoming the package, acknowledging its importance to achieve the
objectives on AML field. Our comments below aim to facilitate the application of the provisions as
smoothly as possible. The accountancy profession remains committed to fighting money laundering
and Accountancy Europe remains at your disposal for further discussion on any of the following or
other points....