We further request that national additions to data points be limited to highly exceptional and justified cases, as they do not reflect the intent behind the harmonization of the reporting template for reporting suspicions in the European Union and may lead to issues in cases where suspicions must be reported in multiple jurisdictions. Finally, the response provides detailed input on definitions, processes, legal aspects, and 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 that the AMLA develop a tailored template for reporting suspicious transactions that is suited to the activities of our members.
