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EBA invites comments on revised Risk Factors Guidelines on money laundering and terrorist financing – consultation open until 6 July 2020


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On 5 February 2020, the European Banking Authority (EBA) issued a public consultation on revised Risk Factors Guidelines on money laundering and terrorist financing (JC 2019 87).

The Guidelines issued by the European Supervisory Authorities on 26 June 2017 on money laundering and terrorist financing risks factors as well as simplified and enhanced customer due diligence measures have been updated. The revised Guidelines reflect changes in the EU’s anti-money laundering and counter terrorist financing legal framework as well as new money laundering and terrorist financing risks identified after the original Guidelines.

Key changes

The revised Risk Factors Guidelines include, among other things, new guidance on enhanced customer due diligence measures related to high-risk third countries.

New sectoral guidelines have been added on:

  • Crowdfunding platforms
  • Corporate finance services
  • Payment Initiation Service Providers (PISP)
  • Account Information Service Providers (AISP)
  • Firms providing currency exchanges services.

The revised Guidelines also provide more details on terrorist financing risk factors and customer due diligence (CDD) measures including on the identification of the beneficial owner and the use of innovative solutions to identify and verify the customers’ identity. In addition, the guidelines have been updated in terms of firms’ obligation to prepare business-wide and individual ML/TF risk assessments.

The purpose of the Guidelines is to provide reporting entities with tools to assess the ML/TF risks related to their operations and customer relationships as well as monitoring methods and other controls needed in risk management. Furthermore, the Guidelines support competent authorities’ AML/CFT supervision efforts when assessing the adequacy of risk assessments prepared by entities under their supervision and the adequacy of the ML/TF risk management measures.

Draft Guidelines, consultation period and public hearing

The draft Guidelines and more detailed instructions on submitting comments are available at the EBA website. The consultation period runs until 6 July 2020.

There will be a public hearing on the draft Guidelines via conference call on 15 May 2020. The EBA will communicate the dial-in details on its website.

For further information, please contact

Jonna Ekström, Senior Legal Advisor, tel. +358 9 183 5531 or jonna.ekstrom(at)

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Regulator Information

Abbreviation: FIN-FSA
Jurisdiction: Finland

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