As an independent group of experts, the Meijers Committee monitors the development and effectiveness of, amongst other areas, EU criminal law, including European Anti Money Laundering (AML) rules. Thus far, these rules were entered via directives and subsequently implemented by the Member States. In July 2021 an ambitious EU AML package was launched. The package introduces, amongst other things, a single rule book – via an AML Regulation – and a new overarching EU AML supervisor: the AML Authority (AMLA). Taking into account the ongoing expansion of the scope of the AML rules, the Meijers Committee has concerns that the use of resources is not sufficiently effective, that the risk of citizens being deprived of essential facilities as a result of this expansion is not sufficiently targeted and that the proposed AML package needs adjustments to remove these concerns. In this comment, the Meijers Committee raises three questions:

Are the scarce resources (of both the obliged entities and their supervisors and enforcers) being used effectively at this moment?
Are the individual’s rights, such as privacy, non-discrimination, presumption of innocence and proportionality, at risk of being compromised?
Does the proposed AML package address the abovementioned questions?

In light of the foregoing, specific recommendations are identified, which will be elaborated on in further detail in the attached comment.

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