Towards an Intelligence-Led AML Supervisory and Enforcement Regime across the European Union | Deloitte Netherlands

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Towards an Intelligence-Led AML Supervisory and Enforcement Regime across the European Union

Practical steps for obligated entities to increase their readiness

Beneath the headlines of the global pandemic response, the European Commission (EC) has outlined one of the most profound and ambitious overhauls to the global framework for fighting financial crime. What does their six-point Action Plan consist of and what practical steps can obligated entities take to increase their readiness?

Addressing the challenges of the 21st century

So far, the current framework for fighting financial crime has not been fit-for-purpose, notably in addressing the challenges of the 21st century. The global consensus on this claim is actually acknowledged by the new six-point Action Plan composed by the European Commission. The EC Action Plan for a comprehensive European Union (EU) policy on preventing money laundering and terrorist financing spans a 27-member nation market, home to some 450 million consumers.

Towards an Intelligence-Led Supervisory and Enforcement Regime for Anti-Money Laundering across the European Union

Intelligence-led approach

We have decrypted the action plan and propose some practical steps for obligated entities to increase their readiness. The EC’s first priority with this plan is to address divergences in the application and enforcement of its existing rules. However, the Action Plan also recognizes a number of institutional and operational shortcomings. The EC claims to address those through an intelligence-led approach that incorporates the increased use of technology, expanded information-sharing and public-private partnerships.

The six pillars of the action plan

The ambitious and multi-faceted action plan consists of the following six pillars. These are explained in full in our publication “Towards an Intelligence-Led Supervisory and Enforcement Regime for Anti-Money Laundering across the European Union”. 1. Effective implementation of the existing Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) framework. 2. A single EU AML/CFT rulebook. 3. EU-level AML/CFT supervision. 4. Coordination and support for Member State Financial Intelligence Units. 5. Enforcing EU-level criminal law provisions and information exchange. 6. A stronger EU in the world.

Important and much-needed evolutions

The EU action plan echoes many of the findings of one of our publications - the Deloitte Institute of International Finance report. As such, it provides further evidence of important and much-needed evolutions in the global architecture for AML/CFT.

More information

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