In previous blogs and articles, I have relayed one consistent message on the effectiveness of AML/CFT measures – ‘Legislation alone, is not enough.’
I welcome therefore the European Commission’s recently issued action plan which promises fresh measures to fight money laundering and terrorist finance (ML/TF).
The new plan goes deeper than anything we’ve seen before and also includes the methodology to identify high-risk third countries.
Via six pillars, it’s a multi-faceted, far-reaching approach which, encouragingly, goes beyond mere legislation.
I’m pleased to see that the EC has acknowledged that action is now needed on several levels.
The commission is, by the way, inviting feedback on what’s included. If you’re a stakeholder you have until the end of July to have your say.
Here are the six pillars:
- Effective application of EU rules
- A single EU rulebook
- EU-level supervision
- A coordination and support mechanism for Member State Financial Intelligence Units
- Enforcing EU-level criminal law provisions and information exchange
- The EU’s global role.
Centralised approach + more support
The EC is aiming to become the global driver (in co-operation with the FATF) in shaping international AML standards.
It has pledged to appoint an EU-level Supervisor plus rollout new mechanisms to co-ordinate and support Financial Intelligence Units (FIUs).
The new plan also identifies the need for AML/CFT legislation to be more granular, more precise and less subject to diverging implementations.
Whilst this is all good news, I do have one concern.
The EC must strive to do more than simply pile up new rules on top of existing rules. Recent and upcoming changes have already been complex and for the financial services sector, the burden is increasing.
I also hope the appointment of the EU-level supervisor will not end up within the EBA. More on this below.
Deeper detail
Enhanced detail relating to the issue of AML rules by member states also seems to be on the way.
The EU-wide policy however, still needs to resolve inconsistencies in the application of regulations. Detail to close the gaps and create more harmonised rules are proposed in Q1 2021; and we can expect to see this strategy outlined in a single EU rulebook.
The EC also intends to issue guidance on the role of public-private partnerships to clarify and enhance data-sharing.
Once again, this is all very positive and I’m looking forward to studying the new rulebook as soon as it’s available.
Global not local
Criminals do not act locally and information should not stay local.
Access to broader and deeper information can help to catch the more sophisticated criminal networks and in my article published in the Paytech book issued late 2019, I discussed what I believe should happen to boost the fight against financial crime.
Within this article, I also address issues relating to technology and KYC databases, encourage a sector mindset change and advocate the rethinking of compliance.
I also make a call in the book, for not just co-operation between the public and private sectors, but within the private sector itself.
It is further good news therefore, that the new EU action plan reiterates the importance of the appropriate exchange of information and acknowledges the key role the private sector can play.
Concerns over EBA
I mentioned above the EBA and my concerns that the new EU-level supervisor appointment should not sit within the EBA.
I have also shared my concerns about the EBA being an appropriately designated authority for the entire financial services industry in a previous blog and I repeat my worries here: does the EBA have the right mindset to change the mindset?
The new EU plan does discuss potential supervisory models including enhancing EBA’s remit beyond the financial services sector (or a dedicated body with responsibility across all relevant economic sectors). Nothing has however been decided and we are told the proposed structure will be outlined in early 2021.
Will this be enough?
When under 1 percent of global financial crime is actually caught, will all this enhanced activity actually change the statistics?
Whilst I welcome the EC taking a different approach to ensure consistency (and stepping away from tackling ML/TF through legislation alone) will it be enough to make a noticeable difference?
Well… it may be a very good start.
With an emphasis on global co-ordination, plus the delivery of support at EU level and horizontal and vertical information exchange, the new action plan does look like the first steps towards a different approach.
This could begin to drive the required mindset change.
Compliance is also key
Whilst collaboration is a key message, more is also needed to drive mindset changes within organisations. Compliance must therefore, be a part of the strategy and seen as a benefit to an organisation, rather than a burden.
The new single EU rulebook should carefully consider the existing compliance workload that businesses are faced with, and not just pile on additional burdens. Also, let’s not forget, that over half of EU member states are yet to implement the 5th AML Directive (and also the 6th Directive which is planned for the end of this year).
Failure to manage the actual implementation of compliance means we risk getting caught in a vicious cycle of a ‘tick-box’ approach to (perhaps to simply satisfy the regulator during an audit) rather than addressing the root cause.
We’ll be watching
Overall, so far so good; and I very much welcome the EC’s new and robust action plan.
We just now need to know, how it will all be implemented.
I will personally be keeping a close eye on the EC’s rollout and the implementation of each pillar.
I suggest you do too.
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