We have submitted our feedback to to AMLAs consultation on ITS under Article 69(3) of the AMLR, concerning the format for reporting suspicions and providing transaction records.
Key points from our response include:
• Proportionality: Extensive mandatory reporting requirements could impose disproportionate administrative and compliance burdens on accountants and smaller practices.
• Data necessity: EFAA calls on AMLA to reassess the necessity of requested data, particularly where accountants may not typically hold the information.
• European harmonisation: Country-specific data points could create challenges for harmonised reporting across Europe.
• Data protection: EFAA calls for clear GDPR guidance on the storage of personal data.
• Regular reviews: EFAA supports regular reviews of data points to ensure requirements remain proportionate and relevant.
Read our full reply here.