ELTI Position Paper: Enhancing the efficiency of measures to fight against Anti-Money Loundering and Countering the Financing of Terrorism

On July 20, 2021, the European Commission published a new legislative package revising the Anti-Money Laundering and Countering the Financing of Terrorism regulation (AML-CFT). National Promotional Banks and Institutions (NPBIs) such as i.e. Caisse des Dépôts Group (CDC), Kreditanstalt für Wiederaufbau (KfW) or Bank Gospodarstwa Krajowego (BGK) are impacted by this initiative in regard to the draft regulation on the prevention of the use of the financial system for the purpose of money laundering (AMLR) and/or the revised regulation on information accompanying transfers of funds and certain crypto-assets (Transfer of funds regulation).

From a general perspective, we welcome the objectives pursued by the European Commission. As public financial institutions, we support the ambition of this new package. The following remarks are intended to enhance the efficiency of the new measures and facilitate the proper conditions for their application. In this perspective, we would like to share three main challenges: 

• The benefits of an approach based on actual risks, which avoids a disproportionate burdening of already efficient procedures for identification or reporting;

• A need for clarification to ensure that new requirements are fully consistent;

• Highlighting points of attention related to the nature of certain NPBIs’ specific activities.