Erhvervsudvalget 2019-20
ERU Alm.del Bilag 391
Offentligt
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Finanstilsynet
HVID
J.nr.
/ERO
Public Consultation questionnaire [Denmark]
Ensuring effective implementation of the exist-
ing rules
How effective are the following existing EU tools to ensure application and enforce-
ment of anti-money laundering / countering the financing of terrorism rules?
Very
ef-
Rather
fective
Infringement proceedings for
failure to transpose EU law or
incomplete/incorrect transposi-
tion
Country-specific recom-
mendations in the con-
text of the European
Semester
effective
Neutral
Rather in-
effective
Not ef-
fective
at all
Don't
know
X
X
Action following complaint by
the public
Breach of Union law investiga-
tions by the European Banking
Authority
New powers granted to the
European Banking Authority
x
x
X
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 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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How effective would more action at each of the following levels be to fight money laundering and terrorist financ-
ing?
Very
ef-
Rather
fective
At national level only
At national level with financial
support and guidance from the
European Union
At the level of the European
Union (oversight and coordina-
tion of national action)
At international level
No additional action at any level
effective
Neutral
Rather in-
effective
Not ef-
fective
at all
Don't
know
X
X
X
X
x
Generally, we believe that actions to fight money laundering and terrorist financing can be relevant and effective on all levels, though
depending on the type of action it can be more effective on a national level or on EU-level.
In order to ensure more effective implementation of rules, we should look into the questions of harmonization, cross-border cooperation,
cooperation with the private sectors and international efforts.
As to harmonization (also see text further below), we should look into raising our minimum standards in order to further strengthen national
and supranational regimes.
As to cross-border cooperation, we should look into strengthening areas that have already proven effective. As an example, AML/CFT
supervisory colleges have proven to be a very effective tool for cross-border supervision and information exchange. We should look into
making these colleges mandatory and enhance our cooperation in them by increasing the intensity of meetings (when relevant, virtual
meetings can be held in between actual college-meetings), joint-inspections and information sharing as well as, when relevant, include
other competent authorities such as prudential supervisors, FIUs etc. Furthermore, we could include the new EU-level supervisor as a
participant in the AML/CFT colleges.
As to cooperation with the private sector, we should look into assisting in building technological infrastructures to focus their AML/CFT
efforts on suspicious customers and keep track of these customers moving from one obliged entity to the other.
As to international efforts, we should look into how we can better and faster implement international standards into our EU regulatory
framework. Also, we should look into raising international standards, in particular where EU-rules are stricter and more effective than
international standards. An example of this is our requirements with regard to beneficial owners.
Should other tools be used by the EU to ensure effective implementation of the rules?
Additional comments
5000 character(s) maximum
including spaces and line breaks, i.e. stricter than the MS Word characters counting method.
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In order to ensure effective implementation it is likewise very important that the interaction between an AML/CFT Directive and other
regulation, such as GDPR, is assessed and taken into account when paving the way forward in order to ensure that potential conflicting
provisions are addressed.
A final remark regarding the questions on the effectiveness of actions at different levels: the added-value depends entirely on how the
action is designed and undertaken. The important part is to focus on the interaction between the various levels and not disrupting well-
functioning value chains
.
Delivering a reinforced rulebook
The Commission has identified a number of provisions that could be further harmonised through a future Regu-
lation. Do you agree with the selection?
Yes
No
Don't know
List of obliged entities
Structure and tasks of supervision
X
X
X
X
X
X
X
X
X
x
X
X
X
Tasks of financial intelligence units
Customer due diligence
Electronic identification and verification
Record keeping
Internal controls
Reporting obligations
Beneficial ownership registers
Central bank account registers
Ceiling for large cash payments
Freezing powers for financial intelligence units
Sanctions
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What other provisions should be harmonised through a Regulation?
We general support transforming parts of the AML/CFT Directive into a Regulation. Obviously, further harmonisation should raise minimum
standards and not lower actual standards in Member States with strong national regimes. Going from a (minimum harmonisation) Directive to
a Regulation should not lead to a less (strict) regulation in Member States.
If the high standards of the additional national rules in Member States that goes beyond the Directives minimum standards can be ensured, we
support moving certain parts of the EU AML/CFT framework into a Regulation - especially in certain areas where EU Regulation is already
implementing common global standards, e.g. from FATF. This will also make the implementation of changes in the FATF recommendations
speedier.
It should be noted that a Regulation lacks the opportunity for national adaptation, e.g. use of national digital and data systems. Therefore, it is
important to maintain a risk-based as well as technology and data infrastructure neutral approach.
It is also important that any (possible) conflicting regulation is taken into account, when assessing the way forward.
The area covering the obligations on obliged entities could merit further harmonisation. Especially, the regulatory understanding and require-
ments relating to costumer due diligence (CDD) is e.g. an area which could merit further alignment in our view, as there seems to be some
differences in the way the requirements are understood. This could furthermore provide better opportunities for the development of com-
mon/shared technology and infrastructure. New digital infrastructure would help companies to better fight ML/TF by sharing information (e.g.
regarding CDD).
It is also our experience that there should be a better opportunity for obliged entities to exchange specific information across Member States in
order to concentrate efforts on companies and customers considered suspicious.
Furthermore, increased harmonisation could be beneficial for all Member States with regard to supervisory responsibilities in cross border
situations, i.e. home/host supervision, as well as in situations where obliged entities operate establishments in other Member States through
networks of (passported) agents. There seems to be ambiguity as to whether agents should be under national supervision. Some Member
States require agents to be under national legislation but others do not. The possibilities for host authorities to address obliged entities in other
Member States with agents in the host Member State should be improved.
In continuation of the abovementioned, we are also positive towards discussing harmonization regarding:
AML/CFT Directive:
Articles 1-5
(general provisions) are necessary in both the Directive and the regulation.
Article 9
(third country policy) We see the area of high-risk third countries as part of the Directive, which would merit further harmonisation and
where there is a certain degree of harmonisation already. Third country policy could possibly be transferred to a Regulation since harmonised
provisions in relation to third countries would help strengthen the EU's "external border"..
Article 50
(Cooperation with the ESAs) could be placed into a Regulation. There should be harmonized rules for cooperation with ESAs.
Articles 51-57
(Cooperation between FIUs and the Commission) could be placed into a Regulation as it does not preclude increased harmoni-
sation in terms of the Commission report on FIUs.
Article 57a-57b
(Cooperation between Competent authorities supervising credit and financial institutions and other authorities bound by pro-
fessional secrecy) could be placed into a Regulation. There should be harmonised rules for enhanced cooperation between competent
authorities and other relevant authorities.
Articles 63-69
(Final provisions) are necessary in both the directive and the Regulation.
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What provisions should remain in the Directive due to EU Treaty provisions?
-
Articles 6-8
(risk assessments) Even though we do see differences in national regimes regarding this point, these provisions seem to
mostly belong in a Directive. We should however focus on enhancing guidelines and best practices. Further harmonization could hinder
innovative national solutions.
Articles 40-44
(Data protection, record-retention and statistical data) seems to be best achieved by being able to adapt them to national
practice and could therefore be preserved in the Directive.
Articles 47-48
(supervision) We should 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 and the
supervisory powers could in general remain in a Directive.. The scope for the EU-supervisory body should be transferred into a Regulation
e.g. direct supervision of some obliged entities, coordinating cross-border efforts including national oversight and assisting with expert
assistance in complex international cases.
Article 49
(national cooperation) should be kept in the Directive as Member States should have a say in how to organise themselves
nationally. We note that it may lead to differences in the supervisory landscape across the EU (or rather, a continuation of the existing
landscape).
Article 58-62
(sanctions) should be kept in the Directive. We see a challenge in relation to harmonisation of administrative sanctions. In
our view, this is an area where it is important to keep national discretion. MS have different legal and sanctioning practices that needs to
be taken into consideration.
-
-
-
-
What areas where Member States have adopted additional rules should continue to be
regulated at national level?
In general, we should be cautious towards limiting the possibility for MS to adopt additional, more stringent rules.
As such, a possible future Regulation should raise the bar and create a level playing field notwithstanding some
flexibility for stricter national rules. This flexibility is needed in situations where 1) a national context warrants it
and 2) where international standards are not yet implemented into EU-law (resulting in Member States not being
in compliance with i.e. FATF recommendations).
As to the first situation, in Denmark, we have adopted a complete ban on the use of the 500 EUR note as this
was a measure commensurate to the risk and context in Denmark.
Furthermore, for entities not covered by the Danish AML-act, a cash limit (prohibition) of 50.000 DKK has been
set for payments that take place at once or as several payments which appear to be linked,
As to the second situation, we need a swifter adoption of FATF recommendations than what is currently the
case.
In Denmark we have implemented additional national rules ensuring that designations pursuant to all UN sanc-
tions regimes are implemented in Denmark without delay. Furthermore, in relation to virtual asset service pro-
viders, we see that many MS adopts additional national rules to include these as obliged entities under national
AML/CFT laws.
On a final note, as described above, rules regarding sanctions (and the possibility to adopt additional national
rules in relation hereto) should be kept in the Directive, as there are significant differences in what sanctions are
proportional, dissuasive and effective from MS to MS. There must be a discretion to consider sanctioning policy
for AML/CFT in light of other domestic sanctioning policy and the use of other tools to incentivise compliance.
As such, we especially consider that the assessment of the seriousness of breaches intervenes with national
criminal justice systems.
In addition to this, we would like to note that in Denmark, through a number of political agreements, we have
adopted several additional sanctioning possibilities. An example of this is the possibility for the DFSA to order a
temporary stop for new customers.
Should new economic operators (e.g. crowdfunding platforms) be added to the list of
obliged entities?
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 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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Generally, we do not find it necessary to add new economic operators to the list of obliged entities in cases
where the operators are not in possession of funds. Parties handling funds on behalf of operators already fall
under the remit of existing AML/CFT frameworks through regulations bespoke to the given activity. For example
crowdfunding platforms that handle the transfer of funds between the owners of the marketed projects and the
lenders/investors, are regulated under either PSD2 or MiFID (which will also be the case when the crowdfunding
regulation takes effect).
However crowdfunding platforms and similar economic operator might need extra consideration since they are
only regulated under the new crowdfunding regulation, and will not be allowed to handle funds on behalf of the
participants. This could open the door for criminals wanting to abuse such platforms to create fake investments
or loans with illegal proceeds, by both being the owner of marketed projects on crowdfunding platforms and the
investor/lender. Thus, the platform could successfully have registered an agreement by both parts, but as they
do not handle the underlying transactions, they cannot validate that the proceeds has actually been transferred.
In your opinion, are there any FinTech activities that currently pose money launder-
ing / terrorism financing risks and are not captured by the existing EU framework?
Please explain
Some types of activity that are not sufficiently captured by the current EU framework regarding AML/CFT are
those concerning crypto-assets. The FATF standards on VASPs are not fully implemented in the current AMLD.
It would be beneficial to see a further EU level implementation of the standards, since national regulation can
cause a fragmented framework and lead to an unlevel playing field.
The Commission has identified that the consistency of a number of other EU rules
with anti-money laundering / countering the financing of terrorism rules might need
to be further enhanced or clarified through guidance or legislative changes. Do you
agree?
Yes
No
Don't
know
Obligation for prudential supervisors to share information with anti-money laun-
dering supervisors
Bank Recovery and Resolution Directive (Directive 2014/59/EU) or normal insol-
vency proceedings: whether and under what circumstances anti-money launder-
ing grounds can provide valid grounds to trigger the resolution or winding up of a
credit institution
Deposit Guarantee Schemes Directive (Directive 2014/49/EU): customer
assessment prior to pay-out
X
X
X
Payment Accounts Directive (Directive 2014/92/EU): need to ensure the general
right to basic account without weakening anti-money laundering rules in suspi-
cious cases
Categories of payment service providers subject to anti-money laundering
Integration of strict anti-money laundering requirements in fit&proper
tests
rules
X
X
X
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Are there other EU rules that should be aligned with anti-money laundering / countering
the financing of terrorism rules?
We see an overall need for a clarification of the interplay between AML rules and GDPR, in particularly in
regards to banks' Customer Due Dilligence (CDD) utility models. This is an important aspect that needs to
be addressed if GDPR rules create undue barriers, which inhibit AML/CTF efforts.
In this context, a central register linking national bank accounts would be a decisive advantage when com-
bating international crime and ML/TF.
Additional comments
We find that there is a need for an overall virtual currency framework in order to facilitate and provide the
basis for the tools needed to address and combat possible ML/TF by the use of virtual currencies.
While AMLD5 does provide some regulation in this regard, we note that FATF's requirements for regulating
virtual assets go beyond the Directive, which can create some problems for Member States.
In general, we believe that the EU should adopt FATF recommendations quicker than is currently the case,
in order to ensure that national AML/CFT frameworks are FATF-compliant at all times.
We believe that harmonisation and development of common technological infrastructure should likewise be
a key priority. As such, the Commission should investigate and possible launch an initiative to support
technological infrastructure developments to more effectively combat ML/TF
We are open to discuss whether the removal of restrictions to cooperation among competent authorities is
sufficient or whether the legislative framework should introduce explicit obligations for competent authorities
to exchange information and to cooperate. This could be done in the form of making supervisory colleges
obligatory for international banks and for other obliged entities (e.g. money remitters with agents in host
Member States) where this would be relevant, on a risk-based approach.
As the proliferation of financing of weapons of mass destruction is steadily becoming a part of the risk based
approach in FATF, we should consider if and how this aspect could be covered by the AMLD/AML-
regulation.
Bringing about EU-level supervision
What entities/sectors should fall within the scope of EU supervision for compliance with anti-money laundering /
countering the financing of terrorism rules?
All obliged entities/sectors
All obliged entities/sectors, but
through a gradual process
X Financial institutions
Credit institutions
What powers should the EU supervisor have?
at most 1 choice(s)
Indirect powers over all obliged entities, with the possibility to directly
intervene in justified cases
Indirect powers over some obliged entities, with the possibility to directly
intervene in justified cases
Direct powers over all obliged entities
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Direct powers only over some obliged entities
X
A mix of direct and indirect powers, depending on the sector/entities
How should the entities subject to direct supervision by the EU supervisor be identi-
fied?
They should be predetermined
X
They should be identified based on inherent characteristics of their business (e.g.
riskiness, cross-border nature)
They should be proposed by national supervisors
Which body should exercise these supervisory powers?
The European Banking Authority
X
A new EU centralised agency
A body with a hybrid structure (central decision-making and decentralised imple-
mentation)
Other
If other: please explain
We believe that we should look into the possibility of a new dedicated body to be created as the EBA today
does not perform direct supervision but are tasked with supplementing the regulation through regulatory
technical standards and guidelines, and ensuring supervisory convergence between the supervisory au-
thorities performing supervision in the EU. Furthermore, if the new EU-level supervisor is to possibly expand
its range of supervision to i.e. DNFBPs, this could prove challenging for EBA as these fall outside of their
scope.
An EU AML supervisor could be a key initiative in fighting money laundering and terrorist financing in the
EU. We therefore support exploring the establishment of an EU AML supervisory body with certain powers.
We support that a European AML body should focus its efforts on the financial sector where the added
value and relevance could be particularly high.
We support and recommend a step by step expansion of the scope of EU-level supervision to other sectors
and entities, although we believe supervision of financial institutions is the proper starting point for EU-level
supervision. We believe expansion of the scope of EU-level supervision to other sectors and entities should
await and be based on experience and results gained from EU-level supervision of financial institutions. We
are still analyzing which sectors and entities are relevant to potentially be included in the scope of EU-level
supervision.”
The step-by-step approach should further more depend on the risk that these sectors pose, the nature of
certain sectors and depending on the knowledge and results from EU-supervision with financial institutions.
In general, we support conferring certain AML supervisory tasks and powers to an EU supervisory body.
An EU AML supervisory body has the potential to add value and significantly strengthen our EU AML regime
if properly designed.
Additional comments
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As such, it should be given a mix of direct and indirect powers, depending on the sector/entities primarily
action on a comply or explain basis through NCAs. Such a body could have direct powers towards institu-
tions based on a predictable framework. Direct powers could be especially relevant for cross border insti-
tutions.
We are still analysing what would be the most optimal organisational choice for a possible EU AML super-
visory body. The question also links intrinsically to the question regarding which obliged entities and sectors
it should encompass.
There are advantages and disadvantages to the different possible solutions that needs to be further and
comprehensively analysed. However, we find that a solution with EBA having direct supervision authority
will be difficult with the current organisational set-up and governance structure. An AML/CFT supervisory
body needs an independent and transparent set-up, and we find that a solution should be found in a new
AML/CFT supervisory body, if the body is to have direct supervision powers.
Other perspectives which should be considered are the costs involved relative to the benefits, and how an
EU supervisory body could be introduced without leading to a duplication of processes or loss of local
knowledge of the supervised entities ect. 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 au-
thorities should continue to play a key role in a new integrated AML system.
Obliged entities which are in the scope of the EU-level supervisor should be selected on a risk based ap-
proach, more specifically on the inherent risk that the obliged entity poses to the financial markets.
General coordinating with national supervisors e.g. in cross-border cases, and assisting with expert assis-
tance in complex international cases and clarify disputes regarding supervision could be part of the tasks
and responsibilities of an EU body.
Any way forward should result in a creating a framework for sharing and developing best practices.
An EU body could also play a key role in assisting/supporting the financial sector in building a common
infrastructure that can strengthen customer due diligence processes with respect to legal certainty for indi-
vidual customers.
Establishing a coordination and support mechanism for financial in-
telligence units
Financial intelligence units (FIUs) play a key role in the detection of money laundering and identification of
new trends. They receive and analyse suspicious transaction and activities reports submitted by obliged en-
tities,
produce
analyses
and
disseminate
them
to
competent
authorities.
While financial intelligence units generally function well, recent analyses have shown several weaknesses.
Feedback to obliged entities remains limited, particularly in cross-border cases, which leaves the private sec-
tor without indications on the quality of their reporting system. The cross-border nature of much money laun-
dering cases also calls for closer information exchanges, joint analyses and for a revamping of the FIU. net
–
the EU system for information exchange among financial intelligence units. Concerns regarding data pro-
tection issues also prevent Europol, under its current mandate, to continue hosting this system.
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An FIU coordination and support mechanism at EU level would remedy the above weaknesses. Currently, the
only forum available at EU level to coordinate the work of FIUs is an informal Commission expert group, the
FIU platform.
This section aims to obtain stakeholder feedback on a) what activities could be entrusted to such EU coor-
dination and support mechanism and b) which body should be responsible for providing such coordination
and support mechanism.
Which of the following tasks should be given to the coordination and support mecha-
nism?
☒
Developing draft common templates to report suspicious transactions
☒
Issuing guidance
☒
Developing manuals
☒
Assessing trends in money laundering and terrorist financing across the
EU and identify common elements
☒
Facilitating joint analyses of cross-border cases
☒
Building capacity through new IT tools
☒
Hosting the FIU.net
Which body should host this coordination and support mechanism?
The FIU Platform, turned into a formal committee involved in adopting Commis-
sion binding acts
☒
Europol, based on a revised mandate
A new dedicated EU body
The future EU AML/CFT supervisor
A formal Network of financial intelligence units
Additional comments
5000 character(s) maximum
including spaces and line breaks, i.e. stricter than the MS Word characters counting method.
at most 1 choice(s)
We welcome the efforts to strengthen the fight against international financial crime. In this fight, the national
FIUs play a significant role.
We support the idea of increased coordination and support at EU level. However, it is important to clarify
the scope and design of such a mechanism in order to ensure that it will facilitate cooperation between
FIUs, on the one hand, and that, on the other, it will support the work on national FIUs operational work,
thereby supporting ongoing efforts in the field.
On the present basis and subject to further assessment we have a preliminary preference for placing this
coordination and support mechanism at Europol, provided that a number of issues, among others that the
concerns regarding data protection, is solved.
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Enforcement of EU criminal law provisions and information ex-
change
Recent actions have increased the tools available to law enforcement authorities to investigate and prosecute
money laundering and terrorist financing. Common definitions and sanctioning of money laundering facilitate
judicial and police cooperation, while direct access to central bank account mechanisms and closer cooper-
ation between law enforcement authorities, financial intelligence units and Europol speed up criminal investi-
gations and make fighting cross-border crime more effective. Structures set up within Europol such as the
Anti-Money Laundering Operational Network and the upcoming European Financial and Economic Crime
Centre are also expected to facilitate operational cooperation and cross-
gations.
Public-private partnerships are also gaining momentum as a means to make better use of financial intelli-
gence. The current EU framework already requires financial intelligence units to provide feedback on typolo-
gies and trends in money laundering and terrorist financing to the private sector. Other forms of partnerships
involving the exchange of operational information on intelligence suspects have proven effective but raise
concerns as regards the application of EU fundamental rights and data protection rules.
This section aims to gather feedback from stakeholder on what actions are needed to help public-private
partnership develop within the boundaries of EU fundamental rights.
bord e r
investi
What actions are needed to facilitate the development of public-private partnerships?
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Put in place more specific rules on the obliga-
tion for financial intelligence units to provide
feedback to obliged entities
Regulate the functioning of public-private partner-
ships
☒Issue
guidance on the application of rules with respect
to public-private partnerships (e.g. antitrust)
☒Promote
sharing of good practices
Additional comments
5000 character(s) maximum
including spaces and line breaks, i.e. stricter than the MS Word characters counting
method.
National public-private partnerships should be able to be established with due regard to national cir-
cumstances and of course in accordance with current legislation.
In addition, it should be possible for national law enforcement authorities to assess for themselves,
which obliged entities should participate in public-private partnerships.
Strengthening the EU's global
Very
ef-
Rather
fective
Give the Commission the task
of representing the European
Union in the FATF
effective
Neutral
Rather in-
effective
Not ef-
fective
at all
Don't
know
X
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 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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13/13
Push for FATF standards to
align to EU ones whenever the
EU is more advanced (e.g. in-
formation on beneficial owner-
ship)
X
Additional comments
We strongly oppose giving the Commission the task of representing the
European Union in the FATF if this is meant as representing MS as “one
member”.
We fully support a stronger EU/COM in the FATF (also in regard to in-
creased coordination with MS), but the work in FATF cover more than our
common directive-based rules. The work in FATF also cover MS inde-
pendent foreign policy. Furthermore, we risk losing European influence
and undermine the very outcome that we desire.
We fully support pushing for FATF standards to align more with EU ones,
where the EU is more advanced. Again, this is best achieved by enhancing
coordination and cooperation between the Commission and MS. In this
regard, the Commission should look into increasing coordination and co-
operation with MS who are not members of the FATF.
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