The European Banking Federation has submitted feedback on the Anti-Money Laundering Authority's draft regulatory technical standards on group-wide minimum requirements and additional measures for subsidiaries and branches in third countries under the Anti-Money Laundering Regulation. The federation supports a framework anchored in the risk-based approach, but argues that parts of the draft go beyond the regulation, including a proposed mandatory group AML/CFT officer and additional measures for branches and subsidiaries of EU obliged entities and parent undertakings located in third countries. Its response also calls for a practical parent undertaking model with clear governance and coordination arrangements to support consistent implementation of group-wide policies and procedures. The federation says entities should not be held responsible for implementation across affiliates without the authority or means to ensure compliance. It also recommends that AMLA publish and maintain a list of third countries that restrict intra-group information sharing and reassess the additional measures for third-country branches and subsidiaries to better align them with the risk-based approach.
European Banking Federation2026-06-22
European Banking Federation urges AMLA to revise draft groupwide AML standards around a risk based approach
The European Banking Federation has asked AMLA to revise its draft standards on group-wide AML requirements and third-country branches and subsidiaries, arguing that some proposals go beyond the Anti-Money Laundering Regulation. It specifically objects to a mandatory group AML/CFT officer, seeks a workable parent undertaking model with clear authority, and wants AMLA to list third countries that restrict intra-group information sharing.