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Brussels, 11 June 2025 – The European Banking Federation (EBF) has submitted its response to the European Banking Authority (EBA) on the proposed Regulatory Technical Standards (RTS) in the context of the EBA’s response to the European Commission’s Call for advice on the new AML Authority (AMLA) mandates. The EBF welcomes the EBA’s efforts to strengthen the EU’s AML/CFT framework through the RTS. EBF concerns remain with respect to the clarity and feasibility of the proposed measures which should not impose a disproportionate burden on society.
Key Concerns and Recommendations:
EBF supports the EBA’s goal of a robust and harmonised AML framework. We emphasise that the RTS must be practical, proportionate, and risk-based to be effective.
Our recommendations aim to ensure that compliance efforts are focused where they matter most (i.e. the most substantial risks) while avoiding unnecessary complexity and cost.
The EBF remains committed to working with the EBA, AMLA, and the Commission to ensure the successful implementation of the AMLR and the development of a coherent, efficient, and effective AML/CFT regime across the EU.
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For more information please contact:
Roger Kaiser, Head of Tax and Compliance, r.kaiser@ebf.eu
Nicholas Soutar, Policy Adviser, n.soutar@ebf.eu
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About the EBF:
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The federation is committed to a thriving European economy that is underpinned by a stable, secure, and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.
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]]>Brussels, 30 January 2025 – The Europol Financial Intelligence Public Private Partnership (EFIPPP) has developed a “Practical Guide for Operational Cooperation between Investigative Authorities and Financial Institutions” to facilitate the criminal law investigative authorities in contributing to operational public-private partnerships (PPPs) in the EU.
The Guide is designed to empower criminal law authorities across the EU to engage more effectively in PPPs and lays the groundwork for transformative cooperation in the fight against financial crime.
It builds on foundational work, such as the 2022 staff working paper produced by DG FISMA, representing the preeminent resource for EU criminal law authorities to assess anti-money laundering (AML) / countering the financing of terrorism (CFT) PPPs, particularly in terms of how they can play a role in contributing to – or establishing – these cooperative mechanisms. Of particular relevance is the fact that the Guide is formulated to account for the nuanced approach required in civil code jurisdictions for these matters. It builds on EFIPPP’s own experience as a successful PPP, as well as other existing cooperative mechanisms. EFIPPP’s mix of expertise, in which the EBF is heavily involved, allows it to provide useful insights in the Guide that can be addressed to policymakers, investigative authorities, as well as private stakeholders, outlining suggestions on how best to enhance operational cooperation both from a legal and practical perspective.
The European Banking Federation (EBF) was involved in the editorial team behind the Guide, along with the Royal United Services Institute (RUSI) Future of Financial Intelligence Sharing (FFIS) programme, and Deloitte. The Guide is accompanied by a “Technical Annex: European Survey of Operational Public-Private Cooperation to Tackle Financial Crime in 2024”, which provides extensive insights into existing PPPs, standing as one of the most comprehensive surveys on operational PPPs in the field of financial crime to date.
With the support for the Guide from both DG FISMA and DG HOME, as well as the substantial opportunity created by the Anti-Money Laundering Regulation (AMLR) Article 75, there is a clear impetus moving towards encouraging AML/CFT cooperation mechanisms/PPPs becoming the “new normal” across the EU.
This collaborative effort, led by Dr. Benjamin Vogel (Max Planck Institute), alongside contributors from RUSI, Deloitte, and the EBF, signals a turning point in Europe’s approach to combating financial crime.
The EBF hopes that this document marks a new stage in the fight against financial crime. Now is the time for policymakers and industry practitioners to step forward to help build and strengthen PPPs across Member States. The Guide takes a positive step in putting partnerships at the forefront of Europe’s fight against financial crime.
Wim Mijs, CEO, commented: “The EBF is a proud partner of the leading cross-border community fostered by EFIPPP in the fight against financial crime. The insights shared in today’s Practical Guide highlight the power of trust and collaboration when working with European authorities. This guide offers valuable insights for building impactful operational public-private partnerships and driving meaningful action against financial crime.“
For more information:
Roger Kaiser, Head of Tax and Compliance, r.kaiser@ebf.eu
About the EBF:
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.
The EBF produces a daily and a weekly newsletter with European banking news and updates from national banking associations across Europe. CLICK HERE TO SUBSCRIBE
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BRUSSELS, 26 May 2023 – The European Banking Federation (EBF) is fully supportive of the European Commission and the co-legislators’ overarching objective to improve the effectiveness of the current EU AML/CFT framework. Bearing in mind the necessary lead-time and efforts to get the AML Package adopted and implemented, this momentum is a unique opportunity to improve the framework and cannot be missed.
The EBF has carefully studied the positions reached in both the Council and the European Parliament on the new AML Regulation, AML Directive and for the Regulation on establishing a new AML Authority. In doing so, we have carefully identified several key issues of the three proposals from the perspective of European financial institutions:
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For more information please contact:
Roger Kaiser
Senior Policy Adviser – Fiscal & Anti-Money Laundering, R.Kaiser@ebf.eu
Eduard Hovsepyan
Policy Adviser – Anti-Money Laundering, e.hovsepyan@ebf.eu
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About the EBF:
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The federation is committed to a thriving European economy that is underpinned by a stable, secure, and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.
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BRUSSELS, 10 January 2022 – The EBF has provided feedback to the European Commission’s proposed AML Package (AML Regulation, AMLD6, AMLA Regulation, Recast FTR)
The European Banking Federation (EBF) is fully supportive of the Commission’s overarching objective to address the ineffectiveness of the current EU AML framework. Bearing in mind the necessary lead-time and efforts to get the AML Package adopted and implemented, this momentum is a unique opportunity to improve the framework.
According to the EBF, a paradigm shift is needed. This consists in moving away from the existing legalistic and bureaucratic tick-the-box approach which generates massive flows of irrelevant data that Financial Intelligence Units cannot exploit in an efficient manner. Some of the steps proposed in the package are going in the right direction, notably by addressing the existing regulatory and supervisory fragmentation, as well as extending transparency requirements to crypto-assets and crypto-asset service providers.
While the standardisation of key customer identity information for KYC purposes and beneficial ownership information introduced with the proposed AML Regulation is a positive move, the approach is too prescriptive, and the discretion left to the Member States in adopting additional measures may lead to gold-plating, reintroducing fragmentation. Besides, the proposed AMLD6 maintains the status quo about Beneficial Owner (UBO) registers. In the EBF’s view, UBO registers need to be not only harmonised and interlinked, but also significantly strengthened.
The set-up of a new EU AML Authority (AMLA) is a crucial component of this package. It is hence of great importance that it brings true value to the effective fight against financial crime and does not simply introduce another layer of ex-post reporting.
The EBF maintains that it is key to develop an intelligence-led approach to effectively mitigate money laundering risks and detect financial crime. However, the package does not address some fundamental dimensions of information sharing which must leverage new technologies and involve all actors of the AML framework, including law enforcement and public-private partnerships.
For more information:
Roger Kaiser, Senior Policy Adviser – Fiscal & Anti-Money Laundering, R.Kaiser@ebf.eu
Eduard Hovsepyan, Policy Adviser – Anti-Money Laundering, e.hovsepyan@ebf.eu
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About the EBF:
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere. Website: www.ebf.eu Twitter: @EBFeu.
Every Friday at noon you can receive the EBF Weekly + Financial Regulation Agenda. This agenda presents an overview of upcoming European and international meetings and conferences in financial regulation, as well as important general financial and economic events and key EBF meetings for the week ahead. CLICK HERE TO SUBSCRIBE
The EBF Morning Brief is published Monday through Friday morning and brings you the top banking headlines, relevant announcements from the EU institutions and the latest from the EBF and its members, national banking associations in 32 countries in Europe. CLICK HERE TO SUBSCRIBE
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Brussels, 10 January 2022 – The EBF has responded to the Commission consultation on guidance on rules for Public-Private Partnerships in the AML/CFT domain.
The EBF stresses that information sharing in the context of fighting financial crime is critical in ensuring the effectiveness of the AML/CFT rules. Weaknesses in information sharing between obliged entities, financial intelligence units and law enforcement authorities may inadvertently facilitate the activities of criminals who operate nationally or across borders.
At present, obliged entities send large numbers of SARs to FIUs with no or insufficient quantitative feedback. This situation does not allow obliged entities to focus on the most relevant predicate offenses and leads to an increased number of false positives. Often finding the relevant information for law enforcement authorities may feel like finding a needle in a haystack. If an intelligence-led approach were applied in the AML/CFT framework, obliged entities could receive information on current trends and typologies, as well as operational data which would allow them to focus their efforts on priorities as defined by law enforcement authorities. As a result, obliged entities would be able to send back more actionable data and do it in a smarter and aligned with data minimisation requirements way, reporting information when truly necessary.
The complex nature of money laundering and terrorism financing, often involving cross-border flows of funds and the involvement of many layers of entities, makes it challenging to detect such crimes when the data available to do so is mainly limited to a regulated entity’s own customer base and available open-source intelligence. Being able to enrich this view with information from other private sector entities and competent authorities enhances the likelihood of effective detection for all parties involved in a public-private partnership. It also allows both obliged entities and public authorities to form a holistic overall view of the current trends.
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For more information:
Roger Kaiser, Senior Policy Adviser – Fiscal & Anti-Money Laundering, R.Kaiser@ebf.eu
Eduard Hovsepyan, Policy Adviser – Anti-Money Laundering, e.hovsepyan@ebf.eu
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About the EBF:
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.
Every Friday at noon you can receive the EBF Weekly + Financial Regulation Agenda. This agenda presents an overview of upcoming European and international meetings and conferences in financial regulation, as well as important general financial and economic events and key EBF meetings for the week ahead. CLICK HERE TO SUBSCRIBE
The EBF Morning Brief is published Monday through Friday morning and brings you the top banking headlines, relevant announcements from the EU institutions and the latest from the EBF and its members, national banking associations in 32 countries in Europe. CLICK HERE TO SUBSCRIBE
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]]>BRUSSELS, 20 July 2021 – The European Banking Federation (EBF) today expressed support for the objectives of the European Commission’s Anti-Money Laundering and Countering the Financing of Terrorism Package which aims to strengthen the fight against financial crime in Europe. The banking industry representative also emphasised the need for some specifications to be laid down to ensure that the new EU AML Authority plays a useful role in preserving the integrity of the European Union’s financial system and the security of its citizens.
The EBF is pleased to learn that the recommendations outlined in its AML Blueprint have to a large extent been taken into consideration by the European Commission, demonstrating a common view on key topics. Regulatory harmonisation and enhanced coordination of Financial Intelligence Units proposed in the package will create synergies, facilitating the work of law enforcement and competent authorities. With the harmonisation of customer due diligence rules proposed by the Commission, multinational banking groups will be able to develop more consistent group-wide policies and processes. A clear cut between the AML Directive and the AML Regulation included in the package will be necessary to avoid any duplication of obligations under both legal instruments, as well as gold plating by the Member States and new divergences across the EU.
The set-up of the new EU AML Authority will be critical. For the new Authority to bring value, it must facilitate information exchange and help detect cross-border criminal activities. Properly calibrating the scope and competencies of direct supervision of selected entities will be crucial. The agency should also avoid overlaps and duplications with national supervisors as well as ensure coverage of the non-financial sector. The selection of supervised entities should follow a risk-based approach rather than focusing on the size of entities. It is essential to note that the largest entities are not always the ones carrying the largest AML/CFT risk. Adequate staffing and funding of the new authority will likewise be important. However, the duplication of banking levies should be avoided. Contributions should also be requested from other regulated financial and non-financial businesses and professions.
It is crucial to ensure that today’s package is followed by appropriate actions to enable information sharing, fostering Public-Private Partnerships and supporting the wider use of machine learning and AI technologies in the AML/CFT space, including the setting up of data sharing utilities. Personal data protection rules are often interpreted too restrictively and must be re-calibrated to ensure more balanced interactions between the AML/CFT framework and the GPDR.
“The success of the Package will now depend on the ability of the Parliament and the Council to translate the proposals into a much more effective AML/CFT framework, clarifying the grey zones in the rulebook and supporting effective cross-border cooperation, information sharing and public-private partnerships,” says Wim Mijs, CEO of EBF. “For the EU AML Authority to effectively contribute to the fight against financial crime, it must make information exchange easier and help detect cross-border criminal activities. It is important to stress that this objective cannot be achieved by simply introducing another layer of ex-post reporting,” he added.
European banks are committed to the fight against money laundering and terrorism financing. Public and private stakeholders must continue to build trust and work hand in hand. The EBF remains at the forefront of this fight and stands ready to provide input on the proposed Directive and Regulations and advice that are necessary to get them right.
For more information:
Ruta Barthet, Senior Media and Communications Officer
r.barthet@ebf.eu
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About the EBF:
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere. Website: www.ebf.eu Twitter: @EBFeu.
Every Friday at noon you can receive the EBF Weekly + Financial Regulation Agenda. This agenda presents an overview of upcoming European and international meetings and conferences in financial regulation, as well as important general financial and economic events and key EBF meetings for the week ahead. CLICK HERE TO SUBSCRIBE
The EBF Morning Brief is published Monday through Friday morning and brings you the top banking headlines, relevant announcements from the EU institutions and the latest from the EBF and its members, national banking associations in 32 countries in Europe. CLICK HERE TO SUBSCRIBE
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]]>BRUSSELS, 12 May 2021 – The Directive on Consumer Credit (CCD) provides a solid framework for fair access to credit for European consumers. We look with concern to unregulated creditors and the consequences that they can bring to the stability and well-functioning of the market. For the sake of market stability and consumers’ safety, all creditors should be supervised and required to respond to the same rules on consumer protection, Know Your Customer (KYC), Anti-money laundering (AML), and reporting requirements – in accordance also with national laws.
For the above-mentioned reasons, we suggest that any effective evaluation of the Directive should focus on the following key points: 1) Avoiding gold-plating practices from the Member States, since the provisions of the Directive should be consistently applied throughout the EU, without creating fragmentation. 2) The timely implementation and enforcement of existing rules to reduce regulatory fragmentation rather than providing additional requirements 3) the supervision of all creditors to ensure the same level of consumer protection. 4) The provision of a future-proof and technology-neutral text that enables the Directive to be effective despite fast technological developments.
Click on the button below for the full position.
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Lucia Pecchini, Policy Advisor – Innovation & Retail l.pecchini@ebf.eu
Every Friday at noon you can receive the EBF Weekly + Financial Regulation Agenda. This agenda presents an overview of upcoming European and international meetings and conferences in financial regulation, as well as important general financial and economic events and key EBF meetings for the week ahead. CLICK HERE TO SUBSCRIBE
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]]>BRUSSELS, 26 July 2019 – The European Banking Federation together with its member bank associations, has joined the No More Ransom campaign, a public-private project launched in 2016 offering free decryption tools for ransomware victims and awareness material. Ransomware is a type of malware that blocks a user’s device until a certain amount of money is paid by the victim, often in cryptocurrencies. Ransomware and other forms of online extortion are surging rapidly across the world, costing individuals and businesses billions each year.
Today at the three year anniversary of No More Ransom, more than 200,000 victims of ransomware recovered their files free of charge. This year alone, Europol added 14 new types of tools on its online portal www.nomoreransom.org. Through this portal, victims can decrypt up to 109 different types of ransomware infections, instructed in 35 languages. GandCrab, one of the most harmful and widespread threats globally, was the first to get its decryption tool in February 2018. Since then nearly 40,000 people have successfully decrypted their files, saving roughly €50 million in ransom payments.
As main targets of cyber attacks, banks are dedicated to maintain high levels of security on all fronts. Bank security and policy experts are convinced that the best way to keep up with the rapid evolution of cyber crime is the close cooperation with public authorities. The No More Ransom Campaign is another example of effective collaboration between law enforcement and private sector. Thanks to the campaign, European banks will be able to raise further awareness and protect their organisations and customers against the rise and amount of cyber criminals and their sophisticated methods.
Europol press release – No More Ransom: 108 million reasons to celebrate its third anniversary
No More Ransom flyer – Need help unlocking your digital life?
No More ransom webpage: www.nomoreransom.org
Media contact:
Nahuel Mercedes, Communications Officer, +32 2 508 37 48, n.mercedes@ebf.eu
About the EBF:
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from 45 countries. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere. Website: www.ebf.eu Twitter: @EBFeu.
Every Friday at noon you can receive the EBF Weekly + Financial Regulation Agenda. This agenda presents an overview of upcoming European and international meetings and conferences in financial regulation, as well as important general financial and economic events and key EBF meetings for the week ahead. CLICK HERE TO SUBSCRIBE
The EBF Morning Brief is published Monday through Friday morning and brings you the top banking headlines, relevant announcements from the EU institutions and the latest from the EBF and its members, national banking associations in 32 countries in Europe. CLICK HERE TO SUBSCRIBE
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]]>BUCHAREST, Romania, 10 May 2019 — European banks, represented by the Board of the European Banking Federation, today urged the European Union to step up its efforts for improving Europe’s global competitiveness as part of the agenda of the next European Commission. Specifically, the EBF Board called on governments in Europe to recognize the key economic role of banks in funding growth and supporting prosperity.
Looking ahead to the upcoming policy cycle in the European Union, the Board reaffirmed the European banking sector’s constructive commitment to sustainably and responsibly financing businesses and households. Specifically, banks recognize their role in society when it comes to developing sustainable finance and supporting the energy transition together with other industries in order to meet international climate change objectives.
Banks are fully committed to supporting further European integration, specifically in the EU financial services markets through the completion of the Banking Union and the creation of an effective Capital Markets Union (CMU). This is particularly important at a time of increasing political and regulatory global fragmentation, in order to ensure that sufficient financing will remain available for the European economy.
Members of the Board also emphasized the sector’s unabated commitment to supporting the fight against financial crime and against money laundering and called on EU policymakers and national governments to move towards a more efficient and coherent framework for Anti-Money Laundering. The banking industry is keen to establish more effective cooperation with public authorities when it comes to dealing with financial crime and tax evasion.
As the start of the 2019-2024 EU policy cycle draws closer the EBF Board also underlined the need for the European Commission to thoroughly analyse the impact of the financial regulation that has been introduced in recent years and to properly determine any unintended consequences. A comprehensive impact analysis is necessary to ensure concrete and proportionate future proposals that will prevent further fragmentation of global markets and regulation, a G20 goal supported by the EU.
Members of the EBF Board acknowledged the importance of further pursuing the digital transformation in the banking sector, in order to provide clients – businesses as well as households – with innovative and secure financial services.
Looking ahead, the Board wants to draw attention to the potential adverse effects of Basel IV on the European economy. Implementing the additional Basel IV measures would mean a further significant increase in capital requirements for European banks of possibly more than 20 percent. This could lead to a severe reduction in the funding available for the economy.
Says Frédéric Oudéa, President of the EBF:
“Significant progress has been achieved in recent years, but there still are many challenges ahead. Governments and policymakers should ensure that banks can operate under the right conditions to sustainably and responsibly finance businesses and households. Ineffective and excessively burdensome regulation clearly has a negative impact on the European economy. An inappropriate transposition of Basel IV for example would undermine the EU’s capacity to finance its economy at a time of increasing fragmentation in the global economy.”
“As banking sector we will be in a very collaborative mood for the coming years. We look forward to working closely together with the renewed European institutions. We are very much willing to engage positively and contribute to building a great future for Europe.”
Says Giovanni Sabatini, Chairman of the EBF Executive Committee:
“We need a new push to reinforce the use of financial markets by companies in Europe. Both banks and capital markets are natural partners in the European financing ecosystem; they are complementary. It is clear though that the European CMU project needs a reset. The fundamental and structural obstacles that stand in the way of an integrated Capital Markets Union need to be identified and removed.”
Every Friday at noon you can receive the EBF Weekly + Financial Regulation Agenda. This agenda presents an overview of upcoming European and international meetings and conferences in financial regulation, as well as important general financial and economic events and key EBF meetings for the week ahead. CLICK HERE TO SUBSCRIBE
The EBF Morning Brief is published Monday through Friday morning and brings you the top banking headlines, relevant announcements from the EU institutions and the latest from the EBF and its members, national banking associations in 32 countries in Europe. CLICK HERE TO SUBSCRIBE
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]]>BRUSSELS, May 2019 – To provide ideas and recommendations to policymakers, regulators and experts on the role of banks in the European Union for the next five years and beyond the European Banking Federation has published a manifesto that outlines the main regulatory priorities for the banking sector in the context of the upcoming 2019-2024 legislative policy cycle.
As the voice of European Banks, the EBF and its members remain fully committed to supporting a more competitive and cohesive EU in the context of Europe’s great diversity. We believe that without a united and coordinated Europe, the most likely outcome would be more fragmentation, more protectionism and therefore underperforming economies to the detriment of citizens. The EBF is committed to help in supporting European economies so that European businesses and citizens are better served by banks. We have set out in this document the sector’s recommendations to address the key challenges Europe is currently facing.
Key recommendations:
To read the full document click on the link below or on the image above.
For more information:
Olivier Thomas, Public Affairs Representative
o.thomas@ebf.eu
+32 2 508 3712
Media contact:
Raymond Frenken, Head of Communications
r.frenken@ebf.eu
+32 2 508 3732
Every Friday at noon you can receive the EBF Weekly + Financial Regulation Agenda. This agenda presents an overview of upcoming European and international meetings and conferences in financial regulation, as well as important general financial and economic events and key EBF meetings for the week ahead. CLICK HERE TO SUBSCRIBE
The EBF Morning Brief is published Monday through Friday morning and brings you the top banking headlines, relevant announcements from the EU institutions and the latest from the EBF and its members, national banking associations in 32 countries in Europe. CLICK HERE TO SUBSCRIBE
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