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Association for Financial Markets in Europe

We generally welcome the guidelines as they are conducive to firms adopting risk based, proportionate and effective AML/CFT policies and procedures, but we have a number of comments in the attached paper.
We generally consider that the guidelines are conducive to competent authorities monitoring compliance with applicable AML/CFT requirements, but again have a number of comments in the attached paper.
We welcome the guidelines in Title III of this consultation paper. AFME members welcome this type of specific guidelines for particular business lines or activities in preference to a legally driven classification of the various sectors of the financial services industry.
Association for Financial Markets in Europe