The EU has announced an Action Plan on AML/CFT which is built, as described in the article below, on six pillars:

  1. Ensuring the effective implementation of the existing EU AML/CFT framework;
  2. Establishing a single EU rule book on AML/CTF;
  3. Bringing about EU level AML/CTF supervision;
  4. Establishing a support and cooperation mechanism for Financial Intelligence Units;
  5. Enforcing Union-level criminal law provisions and information exchange; and
  6. Strengthening the international dimension of the EU AML/CTF framework.

We've been here before, and as the author of the article alludes to, the AML/CTF construct needs, as it has always done, to focus more on the mischief than on the process of identifying it.  

Balancing effective AML/CTF with the process of recording work done in compliance, is a perennial challenge which arguably often detracts from the very purpose of 'ticking the boxes' in the first place.

"But in an effort to adapt to new obligations, has the underlying objective of the regime been overlooked? Are we focusing on what really matters?"

Article originally published on 14 May 2020

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