EBA opinion on key money laundering and terrorist financing risks


On 3 March 2021, the European Banking Authority (EBA) published its biennial Opinion on risks of money laundering and terrorist financing (ML/TF) affecting the European Union's financial sector.

The ML/TF risks identified by the EBA include those that are applicable to the entire financial system, for instance the use of innovative financial services, while others affect specific sectors, such as de-risking. The list also includes ML/TF risks that emerge from wider developments such as the COVID-19 pandemic that has an impact on both firms’ AML/CFT compliance and competent authorities’ supervision.

The Opinion, therefore, sets out recommendations to competent authorities aimed at closing these gaps. Some of the risks identified in this Opinion, such as those associated with virtual currencies and innovative financial services, had already been identified in the previous two Opinions on ML/TF risks and continue to be very relevant today. Others are included in the Opinion for the first time, such as differences in the treatment by competent authorities of financial institutions’ involvement in facilitating or handling tax-related crimes (‘cum-ex/cum-cum’).

Head of Knowledge Management Strategy and Market Infrastructure - SGSS
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