Positions

AML position paper

June 4, 2020

The European FinTech Association (EFA) calls for:

  1. EU-wide harmonization of digital identification methods
    • Minimum set of qualified methods and criteria for the digital identification of customers need to be accepted EU-wide
    • Facilitating third party reliance via mutual recognition of AML-compliant identification procedures across EU member states is key for safe and convenient KYC procedures. The design of applicable “suitable safeguards” as described by recital 35 AMLD should be conclusive on the European level
  2. Transsectoral approach for mutual recognition of ID-levels between different regulated sectors
    • “eIDAS” Regulation (EU) No. 910/2014 and use of Qualified electronic signatures (QES) could provide for identification standard that facilitates interoperability of digital identities across industry sectors, including banking, health, mobility, public and telecommunication
  3. More regulatory guidance regarding application of AML rules to new regulated services, e.g. via circulars or guidelines
  4. Re-consideration of AML Rules for Account Information Service and Payment Initiation Service Providers
  5. Harmonization of Suspicious Transaction Reporting and improving the cooperation between the FIUs according to Art. 52, 53 AMLD

You can find the full EFA's position here.

More Positions

EFA Position Paper on the Instant Payments Proposal

The European FinTech Association (EFA) welcomes and supports the European Commission’ proposal to accelerate the rollout of instant payments for the benefit of citizens and businesses in the EU, including SMEs. EFA would like to feed into the current legislative work on the Instant Payments proposal

January 10, 2023

arrow

EFA Position Paper on the Artificial Intelligence Act

The European FinTech Association (EFA) welcomes the European Commission’s (Commission) legislative proposal on Artificial Intelligence (AI) to promote the development of AI in Europe. We would like to provide with this position paper a set of recommendations.

October 26, 2022

arrow

EFA Position Paper on the Revised Payment Services Directive 2

The European FinTech Association (EFA) welcomes the European Commission’s (Commission) review of the Payment Services Directive 2 (PSD2). PSD2 has delivered a more innovative, competitive payments landscape in Europe, however, challenges remain in its implementation.

July 13, 2022

arrow