We furthermore ask national additions to data points be limited to highly exceptional and justified needs as they do not do justice to the idea behind the harmonisation of the reporting template for reporting suspicions in the European Union and may lead to issues in cases where suspicions are to be reported in multiple jurisdictions. Finally, the response provides detailed input on definitions, processes, legal aspects and on individual data points.
We have submitted our comments on the Anti-Money Laundering Authority’s (AMLA) consultation regarding the draft implementing technical standards on the format for reporting suspicions and providing transaction records under article 69(3) of the Anti-Money Laundering Regulation (AMLR). In our response, we emphasize the specific and distinctive nature of the asset management sector and request AMLA to develop a tailored template for the reporting suspicious transactions that fit the activities of our members.
