Insurance Ireland's response to the AML action plan consultation

Insurance Ireland's response to the European Commissions consultation on the AML action plan.


On the 7th May 2020 the European Commission published its action plan which set out steps to be taken to achieve a comprehensive European Union policy preventing money laundering and terrorist financing and sought feedback on same.

As set out by the Commission, the action plan is a reaction to a number of recent high-profile money laundering cases which have exposed weaknesses of the current system including; fragmentation of rules, uneven supervision and limitations in cooperation across the EU.

The action plan is underpinned by the following six pillars:

  • Effective application of EU rules
  • A single EU rulebook
  • EU level supervision
  • A coordination and support mechanism for Member States Financial Intelligence Units
  • Enforcing EU level criminal law provisions and information exchange
  • The EU’s global role


In response to the consultation, Insurance Ireland supports a risk-based approach in the fight against money laundering and terrorist financing as an effective and robust way of policy-making  Insurance Ireland also highlights the pivotal role of National Competent Authorities (NCAs) in responding to the risks specific to their market and recommend that NCAs remain closely involved in supervision.


It is understood that following feedback to the action plan, the Commission will publish legislative proposals in the first quarter of 2021.


A copy of Insurance Ireland’s response can be accessed here.



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