The EU has announced an Action Plan on AML/CFT which is built, as described in the article below, on six pillars:
- Ensuring the effective implementation of the existing EU AML/CFT framework;
- Establishing a single EU rule book on AML/CTF;
- Bringing about EU level AML/CTF supervision;
- Establishing a support and cooperation mechanism for Financial Intelligence Units;
- Enforcing Union-level criminal law provisions and information exchange; and
- 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.