EMA response to Austrian consultation on 4MLD
We submitted a letter to the Austrian Ministry of Finance on 27 September, welcoming their proposals to no longer include EMIs passporting into Austria on a cross-border basis within the scope of the AML laws.
Although the draft law included the SDD provisions set out in Article 15, it did include the Article 12 e-money exemption. In setting out our arguments, we urged the regulator to consider implementing the exemption.
Regarding the requirement for a local point of contact, we provided arguments similar to those in previous EMA responses to member states’ 4MLD consultations, highlighting that the exchange of information can be facilitated effectively without imposing such a requirement.
The full response can be found here.
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