Published by the Luxembourg Bankers’ Association (ABBL) on 15 June 2026, this consultation response to AMLA’s draft Regulatory Technical Standards on group-wide AML/CFT requirements calls for a realistic and proportionate approach to group-wide governance. The ABBL advocates recognition of the complexity of international structures, including groups headquartered outside the EU and entities operating without direct authority over one another. It also supports workable solutions where confidentiality, banking secrecy or data protection laws restrict information sharing, with a focus on effective risk management rather than formal compliance that may be impossible to achieve in practice.
