Public Consultation on revised Guidelines on money laundering and terrorist financing (ML/TF) risk factors (EBA/CP/2023/11)

The amended draft Guidelines on money laundering and terrorist financing (ML/TF) risk factors by the European Banking Authority (EBA) clarify that all credit and financial institutions, including crypto-asset service providers (CASPs), need to take steps to address their ML/TF risks. The Wolfsberg Group welcomes the opportunity to provide comments and suggestions to enhance these amendments based on the principle of ‘same risk, same activity, same supervision’.