EBF REACTION

EBF Response: Consultation on proposed RTS in the context of the EBA’s response to the European Commission’s Call for advice on new AMLA mandates

x

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:

• Need for harmonised risk assessment: The current delegation of guidance to national supervisors risks fragmentation and increased compliance burdens.
• Operational and cost implications: With 272 data points proposed for assessment of inherent and residual risks, the RTS impose a disproportionate burden on financial institutions under very tight time frames. The EBF urges the EBA to identify a core set of critical data points for initial implementation.
• Clarification on group-wide reporting: EBF seeks clarity on the scope of group-level assessments, especially regarding application to non-EU-based obliged entities, shared clients, and the treatment of intragroup transactions.
• Proportional customer due diligence (CDD): The EBF stresses the importance of a risk-based approach to customer identification and verification. It warns against overly prescriptive requirements that could hinder financial inclusion, customer experience, and increase compliance costs without significantly improving AML outcomes.
• Risk-sensitive measures: The EBF supports Simplified (SDD) for non-high-risk customers and calls for targeted Enhanced Due Diligence (EDD) measures based on actual risk exposure, along with more proportionate standards regarding Politically Exposed Persons (PEPs).
• Sanctions screening: The EBF recommends aligning screening obligations with existing EU best practices and clarifying the scope of screening to avoid unnecessary operational burdens. EBF believes that screening should be focused on the customer and individuals or entities that ultimately own or control the customer, allowing identification of persons with meaningful ownership or control.

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.

X

For more information please contact:

Roger Kaiser, Head of Tax and Compliance, r.kaiser@ebf.eu

Nicholas Soutar, Policy Adviser, n.soutar@ebf.eu

x

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.