European Commission Private Sector Consultation

The European NPO Coalition on FATF was invited by the European Commission (EC) to provide input to an assessment of the risks of money laundering and terrorist financing affecting the internal market and relating to cross-border activities that the EC is currently conducting. This follows the entry into force of Directive (EU) 2015/849 on the prevention of the use of the financing system for the purposes of money laundering and terrorist financing (4th anti-money laundering Directive). This assessment is required by Article 6 of Directive (EU) 2015/849 and shall result in the publication of a report by June 2017. Based on this, the EC will make recommendations to Member States on the measures suitable for addressing the identified risks.

The results of this supranational risk assessment will impact the national risk assessment held by national competent authorities as well as obliged entities who will have to take them into account within the framework of the customer due diligence measures they will apply.

In this context, representatives of the NPO sector were invited by DG JUST to share their views on the EC’s preliminary findings (the risk matrix) and to present information relevant to the sector. The draft preliminary NPO input from the European Coalition on the FATF is here.

See here for the EC’s methodology of the supranational risk assessment and here for the list of preliminary findings regarding money laundering and terrorist financing risks.