Statement on on EU AML Authority Draft Guidelines on Business-Wide Risk Assessment
CFE Statement in response to the consultation carried out by the EU Anti-Money Laundering Authority (AMLA) on draft Guidelines concerning Business-Wide Risk Assessments (BWRA) under Article 10(4) of the Anti-Money Laundering Regulation (AMLR).
CFE welcomes AMLA’s objective of creating a harmonised and risk-based framework while emphasising that the final Guidelines must remain proportionate, practical and sufficiently flexible to reflect the operational realities of non-financial obliged entities, including tax advisers.
A central message of CFE’s submission is that tax advisers are not banks and that methodologies developed for financial institutions should not automatically be applied to professional advisory firms.
Throughout the submission, CFE calls for a proportionate, sector-sensitive and operationally workable approach to Business-Wide Risk Assessments that recognises the distinct nature of the tax advisory profession. CFE emphasises that harmonisation should not come at the expense of flexibility and that the final Guidelines should support effective risk management without imposing banking-style compliance models on non-financial professions.
