The Wolfsberg Group is pleased to share the Comment Letter on the EU AML/CFT Legislative Package that we addressed to key EU officials on October 28, 2022.

The Group welcomes and supports the ambitious proposals to strengthen and harmonise the EU’s AML/CFT framework and regulatory oversight process. In the context of ongoing trialogue negotiations, the aim of our letter is to provide suggestions and observations on the following key issues: i. Harmonisation of supervisory practices and standards; ii. Enhanced information-sharing in line with GDPR principles; iii. Facilitating an effective risk-based approach.

The content of the Group’s submission is in line with individual responses contributed by our 13 members, who have also engaged on the EU AML/CFT Legislative Package with trade associations and international bodies.