28 May 2021

Building an effective Anti-Money Laundering ecosystem From reactive to proactive risk management

Money laundering has devastating consequences for economy and society. It is critical to ensure that the fight against money laundering is effective.

This publication presents recommendations on how to build a more effective anti-money laundering/combating the financing of terrorism (AML/CFT) ecosystem across Europe. Our recommendations aim to better implement the existing AML/CFT legislation. This aligns with the European Commission (EC) intentions for its upcoming proposals: to ensure that the current legislative environment works effectively.

To this end, we propose upgrading the role of: i) non-financial obliged entities – including accountants – ii) supervisors and policy makers. Some of our key recommendations are:

  • obliged entities need to:
    • change from reactive to proactive AML risk management
    • integrate AML into their governance
  • supervisors and policy makers should promote cooperation between Member States and between the public and private sector


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