The ESAs have published their second joint opinion on the ML/TF risks affecting the EU’s financial sector. Its key concerns are around monitoring and reporting of suspicious transactions, particularly for institutions whose business model is based on frequent transactions. The report also says institutions are not good at doing adequate business-wide and sector risk assessments.
Other areas of concern include inconsistent application of assessments of qualifying holdings, and the engagement of authorities with new technology – which can equally help to fight financial crime and cause new risks.