Response to consultation on draft RTS on a central database on AML/CFT in the EU

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Question 7: Do you have any comments on the provisions proposed in Article 12 on the ‘articulation with other notifications’? If so, please provide your reasoning.

With regard to Annex 1 – Part 7 on Any other situation where the weakness is material:

On page 38 option 2: Standardisation of the qualitative information provided, EPIF would also support option 2.

Under this option, the degree of standardization of the information collected is higher, while leaving sufficient room of adding free text by competent authorities.

Questions 8: Do you have any comments on the approach proposed in Article 13 and in particular on the sequential approach described in paragraph 4 of that Article? If so, please provide your reasoning.

EPIF would be supportive of option 2– Sequential approach as it would provide a more standardised approach.

Name of the organization

European Payment Institutions Federation (EPIF)

Type of organisation

other entities