14 October 2004

EBIC comments on proposed new Money Laundering Directive

The European Banking Industry Committee (EBIC) published its comments on the on the proposal for a new EU Directive on Money Laundering. EBIC considers that the Directive should be improved on several points. The most problematic provisions concern the definition of the 'beneficial owner' and of 'Politically Exposed Person'.

EBIC has some concerns about the proposed new definition of serious offences. A very wide range of minor offences will be included in the scope of money laundering predicate offences. This would run in contradiction with the risk-based approach introduced by the Directive.

EBIC welcomes the introduction of a risk based approach in the Directive. However, EBIC strongly recommends not to enter into too many details of the risk based approach, as the notion of risks is in constant evolution and specific to each bank and situation.

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