In a consultation letter to the Ministry of Finance on a proposed new anti-money laundering law and amendments to the Financial Contracts Act, Norges Bank supported the aim of strengthening Norway’s framework against money laundering and terrorist financing but asked for clear confirmation of whether the new EEA-based regime would apply to the bank’s core central banking tasks. It argues that the better reading of the EU Anti-Money Laundering Regulation, consistent with a 2022 European Central Bank opinion, is that central banks are not obliged entities when performing core central bank functions, while other activities assigned under national law could still fall within scope. The bank said that distinction matters because formal coverage would determine whether Norges Bank is subject to anti-money laundering supervision, even though it would in practice largely follow the law’s requirements on a risk-based basis. If core central bank tasks are outside scope, it proposes amending the Central Bank Act so confidentiality rules do not prevent relevant information being shared with Økokrim where money laundering is suspected. On cash limits, Norges Bank supports extending the anti-money laundering threshold to services and considers reducing that threshold from NOK 40,000 to NOK 20,000 defensible. It says limits in different laws should reflect their different purposes rather than be aligned for their own sake, sees possible grounds for setting the Financial Contracts Act cash right somewhat below NOK 20,000, and warns that a harmonised NOK 10,000 limit may not satisfy proportionality requirements while NOK 5,000 is not defensible because it could undermine cash use for financial inclusion and contingency purposes.