A new centralised regime for AML and CFT in the EU?

The EU has announced an Action Plan on AML/CFT which is built, as described in the article below, on six pillars:

1. Ensuring the effective implementation of the existing EU AML/CFT framework;
2. Establishing a single EU rule book on AML/CTF;
3. Bringing about EU level AML/CTF supervision;
4. Establishing a support and cooperation mechanism for Financial Intelligence Units;
5. Enforcing Union-level criminal law provisions and information exchange; and
6. Strengthening the international dimension of the EU AML/CTF framework.

We've been here before, and as the author of the article alludes to, the AML/CTF construct needs, as it has always done, to focus more on the mischief than on the process of identifying it.  

Balancing effective AML/CTF with the process of recording work done in compliance, is a perennial challenge which arguably often detracts from the very purpose of 'ticking the boxes' in the first place.

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