2. #EU #AML PROPOSAL PROMOTES FINANCIAL EXCLUSION OF VULNERABLE COMMUNITIES

Do you have dual citizenship or are you an immigrant to the EU? Your financial rights are further compromised with the upcoming EU AMLR!

Following the outcomes of the #Trialogue, the AMLR no longer includes regulatory safeguards to prevent unwarranted de-risking, ensure non-discrimination, and promote financial inclusion (Recital (32a) and Article (41a) in Chapter III of the AMLR).

In the post-Trilogue draft of the AMLR, all provisions in Recital (32a) concerning the financial protection of vulnerable communities, including all classes of immigrants (dual citizens, refugees, and asylum seekers, among others) have been deleted.

The previous version of Recital (32a) advocated for due diligence measures based on individual risk assessments, which could prevent blanket denials of service and ensure that measures would be proportionate to the actual risks presented by these specific customer categories.

A post-Trilogue of Recital (32a) is more limited compared to the previous version as it focuses more narrowly only on civil society organisations that conduct charitable or humanitarian work in third countries, without explicitly mentioning the broader range of vulnerable groups.

The post-Trilogue version does not adequately address the nuanced balance between mitigating financial crime risks and ensuring financial inclusion for all vulnerable groups.

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