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Aki Corsoni-Husain
Aki Corsoni-Husain
  • Aki Corsoni-Husain

  • Partner
  • Cyprus
George Apostolou
George Apostolou
  • George Apostolou

  • Partner
  • Cyprus
Chiara Deceglie
Chiara Deceglie
  • Chiara Deceglie

  • Partner
  • Luxembourg
Massimiliano della Zonca
Massimiliano della Zonca
  • Massimiliano della Zonca

  • Senior Associate
  • Luxembourg
Philip Graham
Philip Graham
  • Philip Graham

  • Partner
  • British Virgin Islands
Ayana Hull
Ayana Hull
  • Ayana Hull

  • Counsel
  • British Virgin Islands
Katerina Katsiami
Katerina Katsiami
  • Katerina Katsiami

  • Associate
  • Cyprus
Petros Kiteos
Petros Kiteos
  • Petros Kiteos

  • Associate
  • Cyprus
Andrew Knight
Andrew Knight
  • Andrew Knight

  • Partner
  • Luxembourg
Evi Koutsioumpa
Evi Koutsioumpa
  • Evi Koutsioumpa

  • Associate
  • Luxembourg
Joshua Mangeot
Joshua Mangeot
  • Joshua Mangeot

  • Counsel
  • British Virgin Islands
Mirza Manraj
Mirza Manraj
  • Mirza Manraj

  • Counsel
  • Hong Kong
Elina Mantrali
Mirza Manraj
  • Elina Mantrali

  • Associate
  • Cyprus
Vanessa Molloy
Vanessa Molloy
  • Vanessa Molloy

  • Partner
  • Luxembourg
Andrea Moundi Savvides
Andrea Moundi Savvides
  • Andrea Moundi Savvides

  • Associate
  • Cyprus
Marina Stavrou
Marina Stavrou
  • Marina Stavrou

  • Associate
  • Cyprus
Matt Taber
Matt Taber
  • Matt Taber

  • Partner
  • Cayman Islands
Carolynn Vivian
Carolynn Vivian
  • Carolynn Vivian

  • Senior Associate
  • Cayman Islands

EBA’s public consultation on revised ML/TF risk factors guidelines

The European Banking Authority (EBA) issued a public consultation on revised money laundering and terrorist financing (ML/TF) risk factors guidelines as part of a broader communication on AML/CFT issues.

The revised guidelines provide more details on terrorist financing risk factors and customer due diligence (CDD) measures including on the identification of the beneficial owner, the use of innovative solutions to identify and verify the customers’ identity. In addition, they set clear regulatory expectations of firms’ business-wide and individual ML/TF risk assessments.

These guidelines set out factors that firms should consider when assessing the money laundering and terrorist financing risk associated with their business, and with a business relationship or an infrequent transaction with any natural or legal person. They also set out how firms should adjust the extent of their CDD measures in a way that is commensurate to the ML/TF risk they have identified. The main focus is on risk assessments of individual business relationships and occasional transactions, but firms should use these guidelines mutatis mutandis when assessing ML/TF risk across their business in line with Article 8 of Directive (EU) 2015/849.

The factors and measures explained in these guidelines are not exhaustive and firms should consider other factors and measures as appropriate.

These guidelines are central to the EBA’s work to lead, coordinate and monitor the fight against money laundering and terrorist financing. Comments to the draft guidelines can be sent by clicking on the "send your comments" button on the EBA's consultation page.

Please note that due to the current Covid-19 situation the deadline for the submission of comments has been extended to 6 July 2020.

EBA press release can be found here.

Consultation paper can be found here.

Harneys recent blog post on EBA’s new role can be found here.