The European Commission held a consultation with nonprofit organisations (among other private sector entities) on its Supranational Risk Assessment of the Money Laundering and Terrorist Financing Risks affecting the EU on March 14th 2017 and as a follow up written comments were submitted to the European Commission. The objective of the March 14th meeting was to elicit views and concrete proposals on possible mitigating measures that could be suggested to address the risks identified.
At the meeting, the European Commission suggested that potential mitigation measures could take several forms:
- Baseline scenario, i.e. no specific action required except the implementation of the AMLD4 (Fourth Anti-Money-Laundering Directive)
- Non- regulatory options, i.e. non legislative measures that could be suggested at sectorial, national or EU level
- Regulatory options, i.e. legislative initiatives at EU level.
The EFC and other NPOs present made the following points among others:
- Need to follow risk-based approach to see which NPOs are considered to be at a higher risk of abuse
- More thorough analysis needed to see if existing measures for NPOs potentially address the risks identified
- Room for further EU-level regulatory options not envisaged by NPOs given current risks seem sufficiently addressed by national and EU-level regulatory actions and could be further strengthened by non-regulatory options
- Need to consider the wider impact of mitigating measures , which could potentially be counterproductive
- Importance of cross-checking EU initiatives with global Counter-Terrorism Policy, and ensuring policy coherence between various EU initiatives
In terms of process, NPOs noted the need for:
- A more open SNRA consultation process with the wider NPO sector
- The NPO sector to be consulted if the EC paper moves towards EU regulatory action
As a follow up to the meeting, the Global NPO Coalition on FATF under the lead of ECNL, EFC, HSC and CSE sent the following written comments to the European Commission.
The European Commission aims to publish its analysis in June this year.
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