The Supervisory Approach to Anti-Money Laundering: An Analysis of the Joint Working Group’s Reflection Paper

On August 31 2018, a Joint Working Group consisting of representatives of the European Central Bank, the European Commission and the European Supervisory Agencies published a document entitled ‘Reflection paper on possible elements of a Roadmap for seamless cooperation between Anti Money Laundering and Prudential Supervisors in the European Union’. The reflection paper straightforwardly calls for additional resources to be made available to the European Banking Authority to counter money laundering. Suggestions for better
cooperation and information sharing among anti-money laundering and prudential supervisors, however, risk being ineffective, as long as the underlying incentives to engage in international regulatory competition towards low enforcement of anti-money laundering standards are not addressed. To
eliminate the potential for regulatory competition, anti-money laundering supervision needs to be raised to a European level.