The IBFed has been responding to the public consultation issued by the European Commission on its action plan on preventing money laundering (ML) and terrorism financing (TF).

The IBFed is convinced that harmonisation of national legislation and alignment with international best practice on information sharing can support more effective collaboration against ML/TF. It could also provide an enabling and interoperable environment for the exchange and cross-fertilisation of innovative approaches to tackling illicit finance, supporting new technological solutions as well as wider cross-sector collaboration.

A risk-based approach is preferable, helping obliged entities target financial crime risk rather than compliance risk.

AML/CFT and data privacy public policy goals are not mutually exclusive and should be balanced to help protect customers and society from illicit finance. AML/CFT goals serve significant national security and public interest objectives and should be pursued vigorously, in a way that is balances an individual’s rights to protection of personal data and privacy.

Public-private partnerships should be supported to share operational data as well as typologies on general risk indicators and aggregated data on risk trends. In this way public-private partnerships can support international campaigns against cross-border threats, such as money mules, human trafficking, and the illicit wildlife trade.

IBFed feedback on EU AML Action Plan_26 Aug 2020