Erhvervsudvalget 2019-20
ERU Alm.del Bilag 391
Offentligt
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Valdis Dombrovskis
Executive Vice-President for An Economy that Works for People and
Commissioner for Financial Services, Financial Stability and Capital
Markets Union
European Commission
MINISTER FOR INDUSTRY,
BUSINESS AND FINANCIAL
AFFAIRS
24 August 2020
Dear Executive Vice-President Valdis Dombrovskis
It is with pleasure that I send you the Danish government response to the
European Commission’s public consultation on an action plan for a
comprehensive Union policy on preventing money laundering (ML) and
terrorist financing (TF).
Strengthening our fight against ML and TF is a high priority for Denmark,
and this consultation deals with a range of significant aspects and possible
initiatives that we find of key importance.
In recent years, we have done much at national level aimed at preventing
and combating ML and TF, including strengthening our toolbox, our
supervisory intensity and the regulatory framework. This, together with the
adoption and implementation of the fifth AML/CFT Directive, sets a high
bar for our AML/CFT efforts. But more can and must be done.
Given the fact that ML and TF often is cross-border in nature, we find it
important that the European framework is robust and enables institutions
and authorities to combat ML/TF. Therefore, we support transforming
relevant rules in the AML/CFT Directive into a regulation. However,
further harmonisation should not lower standards in Member States with
strong national regimes. Furthermore, it would be relevant also to focus on
the interaction between an AML/CFT regulation and other regulation, such
as GDPR, and address potential conflicting provisions hindering effective
prevention of ML/TF.
A key point in the action plan is the question of conferring certain
AML/CFT supervisory tasks and powers to an EU supervisory body.
Overall, we support the creation of an EU AML/CFT supervisory body.
The possible tasks and responsibilities of such an EU supervisory body
should be considered thoroughly to ensure that it leads to a strengthening
of our AML/CFT efforts. As a starting point, the EU body should focus on
financial institutions with the possibility to expand its responsibility to
other obliged entities afterwards based on a step-by-step approach.
MINISTRY OF INDUSTRY,
BUSINESS AND FINANCIAL
AFFAIRS
Slotsholmsgade 10-12
DK-1216 Copenhagen K
Tlf.
Fax
+45 33 92 33 50
+45 33 12 37 78
CVR-nr. 10 09 24 85
EAN nr. 5798000026001
[email protected]
www.em.dk
 ERU, Alm.del - 2019-20 - Bilag 391: EMs orienterende notat, ministerbrev samt høringssvar vedr. EU-Kommissionens offentlige høring over hvidvaskhandlingsplan af 7. maj 2020, fra erhvervsministeren
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The EU AML/CFT supervisory body should be responsible for direct
supervision, following a risk based approach assessing the activities
performed by the institution. Particular attention should be given to larger
credit institutions with cross-border financial transactions. To be truly
effective, it is of great importance that there is a clear division of tasks and
responsibilities between the EU supervisory body and national authorities.
We should generally ensure an efficient division of labour between such
an EU AML body and national AML authorities with fast and smooth
interactions. National AML authorities should continue to play a key role
in a new integrated AML system.
A key task for an EU body should also be to coordinate between national
supervisor e.g. in cross-border cases and facilitating information exchange
between entities under national oversight, clarifying potential disputes, and
providing expert assistance in complex cross-border cases.
ML and TF poses a threat to the integrity and stability of the financial
system across the world. The EU has a central part to play at both European
and international level and we find that the EU could take an active role in
fostering coordination between Member States at an international level
while maintaining Member States’ individual presence and voice. Creating
a framework to facilitate a faster implementation of international (FATF)
standards should likewise be a priority.
Overall we believe that if executed right, the initiatives in the action plan
could make a real difference in the fight against ML and TF. We look much
forward to the coming realisation of the action plan.
Attached please find our replies to the consultation document. As always,
I remain at your disposal should you have any questions or comments.
Yours sincerely,
Simon Kollerup
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