CFE response on the AMLA Consultation
PAC 2/2026 on the AMLA Consultation on the draft RTS on Pecuniary Sanctions, Administrative Measures & Periodic Penalty Payments
CFE in the Statement expresses support for the objective of establishing a harmonised EU framework for sanctions that is effective, proportionate and dissuasive. At the same time, the Statement emphasises that sanctioning methodologies must reflect the risk-based approach embedded in the AML framework and take into account the specific characteristics of non-financial obliged entities, including tax advisory firms, which are typically small or medium-sized and primarily advisory in nature.
CFE recommends that the RTS provide detailed and transparent criteria for assessing breaches and determining sanctions, including explicit recognition of mitigating factors such as cooperation, remediation and the existence of compliance systems. It also calls for precise definitions of key concepts such as “serious”, “repeated” and “systematic” breaches to ensure consistent interpretation across Member States. In addition, the Statement emphasises the need for sanctioning frameworks to differentiate appropriately between financial and non-financial obliged entities and to align closely with the risk-based approach underpinning EU AML legislation.
