EMA publications
The EMA frequently responds to government and European consultations on regulation that impacts the e-money and payment services industry. Sometimes, we also express our views on issues that are raised in the public domain where we feel it is important to provide an industry input.
Our publications reflect the views of the EMA as whole; individual members’ views may vary from time to time. The public consultation responses are listed below. For further information on these positions, please contact us.
EMA response to draft EC AML Directive
The EMA submitted a response to the European Commission Consultation on Proposal for a Directive on the mechanisms to be put in place by the Member States for the prevention of the use of the financial system for the purposes of money laundering or terrorist financing and repealing Directive (EU) 2015/849.
EMA response to draft EC AML Directive Read More »
EMA response to EBA Consultation on draft Guidelines on Compliance Officers
The EMA submitted a response to the EBA CP on draft Guidelines On policies and procedures in relation to compliance management and the role and responsibilities of the AML/CFT Compliance Officer under Article 8 and Chapter VI of 4MLD.
EMA response to EBA Consultation on draft Guidelines on Compliance Officers Read More »
EMA letter to HMT re Economic Crime Levy
The EMA responded to HM Treasury draft legislation on Economic Crime (Anti-Money Laundering) Levy.
The EMA strongly urge HMT to review the revenue-based model for the levy again, as – according to the definitions of turnover and revenue in the draft legislation – it will have a hugely disproportionate impact on startups in the Fintech and PSP sector, as well as firms that are growing but remain loss-making. This impact is not necessarily reflective of the AML/TF risk posed by these firms either.
EMA letter to HMT re Economic Crime Levy Read More »
EMA response to HMT CP on the MLRs 2017 SI 2022
The EMA responded to HM Treasury CP on Amendments to the Money Laundering Regulations 2017 Statutory Instrument 2022 and to HM Treasury Call for Evidence on the AML Regulatory and Supervisory Regime.
View the EMA response to HMT Amendments to MLRs 2017 – SI 2022
View the EMA response to HMT Call for Evidence on AML Regime
EMA response to HMT CP on the MLRs 2017 SI 2022 Read More »