DUFAS has submitted comments on the Anti-Money Laundering Authority’s (AMLA) consultation regarding the draft guidelines for the Business-Wide Risk Assessment (BWRA) under Article 10(4) of the Anti-Money Laundering Regulation (AMLR). We welcome the emphasis on a risk-based and proportionate approach and have made recommendations to further clarify the guidelines and ensure they remain practical and feasible.
In our response, we call for, among other things, a proportionate application of the BWRA, greater flexibility in group-wide risk assessments, and clarity regarding the use of information sources. In addition, we emphasize the importance of consistent application of the guidelines within the European Union to prevent divergent national interpretations.
Together with KPMG, we have published the paper *Bridging the Gap: How a European Security Fund Can Enable Defense Investments for Asset Managers*. The paper examines how private capital can more easily find its way to where it is needed most—unlisted companies and small and medium-sized enterprises (SMEs)—and what obstacles asset managers currently face in doing so.
DUFAS has submitted comments on the Anti-Money Laundering Authority’s (AMLA) consultation regarding the draft RTS on group-wide AML/CFT requirements under the new European Anti-Money Laundering Regulation (AMLR). We support the RTS’s objective of strengthening effective and proportionate group-wide AML/CFT governance, but at the same time we are asking for greater clarity regarding the application of the rules to the asset management sector.
As DUFAS we welcome the European Commission's proposed revision of the European Sustainability Reporting Standards (ESRS), which strike an appropriate balance between simplifying reporting requirements and preserving the core principle of double materiality. In particular, we strongly support the clarification that investments managed on behalf of clients are outside the scope of mandatory ESRS reporting. This clarification provides much-needed legal certainty for the asset management industry.
