EFAA for SMEs responded to AMLA’s consultation on the draft Regulatory Technical Standards (RTS) on group-wide AML/CFT requirements and branches and subsidiaries in third countries.
While supporting the objective of strengthening the EU AML/CFT framework, EFAA stressed the need for clear and proportionate rules for small and medium-sized accountancy practices (SMPs).
EFAA called for a clear distinction between genuinely controlled groups and independent professional networks, arguing that common branding, methodologies, training or referral arrangements alone should not trigger group-wide obligations.
The response also highlights concerns regarding proportionality, professional confidentiality, legal privilege, and the practical implementation of requirements in cross-border and third-country contexts.
EFAA’s reply to the consultation is available here.