The European Banking Federation has responded to AMLA’s consultation on draft implementing technical standards for reports of suspicions and transaction records, supporting EU harmonization but arguing that the proposed data requirements are disproportionate. It calls for each data point to be assessed for its anti-money laundering and counterterrorist financing relevance and necessity, with reporting limited to information that obliged entities are required or permitted to collect. The federation also wants the standards to avoid duplicate reporting and accommodate groupwide reporting across products, services and legal entities, including potential centralized models. It calls for sufficient implementation time, flexibility for future reporting arrangements and transitional measures that prevent dual reporting and unnecessary operational burdens.