EFAA responded to AMLA’s consultation on the draft guidelines for Business-Wide Risk Assessments (BWRAs) under Article 10(4) AMLR.
EFAA supports the principles underpinning the guidelines and welcomes their emphasis on proportionality, professional judgment, and consideration of the size, nature and complexity of obliged entities. The response highlights the importance of applying a “think small first” approach for small and medium-sized accountancy practices (SMPs), ensuring that compliance requirements remain risk-based and do not create disproportionate burdens. EFAA also stresses the valuable role of professional accountancy organisations and cautions against introducing additional prescriptive requirements or unnecessary information-gathering obligations.
EFAA’s reply to the consultation is available here.