Talking risk in Berlin

Timon Molloy, Editor. We would like to thank Charles Intriago and Money Laundering Alert (www.moneylaundering.com) for their kind permission to attend this event.

The risk-based or risk-sensitive approach, as the EU Third Directive styles it, is not something new, Edna Young, Sector Manager, Financial Crime at the UK Financial Services Authority, observed in the opening session of Money Laundering Alert’s Third European Conference and Exhibition, which was held in Berlin in November. It is inclusion of the term in hard law that is novel, she noted. The regulated sector might be struggling with interpretation of the risk-based approach (RBA) but Young pointed out that regulators also need to apply it in their supervisory activity under Article 37(4) of the Directive. Addressing the concerns that member states’ competent authorities will take divergent approaches she had some words of comfort: a regulatory task force comprising representatives from supervisors in 12 member states will meet to review problem areas, exchange experience and work to achieve consistency in practice on the ground.