In dialogue with the new European Anti Money Laundering Authority „AMLA“

Tommas Kaplan, Managing Partner TURN Advisory represented IVD at the AMLA Roundtable in Frankfurt—engaging with AMLA, BaFin, FIU Germany, the German Federal Ministry of Finance, and associations from both the financial and non-financial sectors.

The key takeaway from the roundtable is that: We still regulate and supervise in sector silos, while criminals operate across sectors.

The financial and non-financial sectors are often analysed, assessed and addressed separately. In practice, however, typical patterns work the other way around: money flows, concealment techniques and assets move between both sectors. If obliged entities only consider their own segment, the bigger picture is lost — and that plays into the hands of criminals.

This is why one point is central now: Implementation must be proportional and defined concretely.

What is feasible for large institutions is not necessarily realistic for small businesses in the non-financial sector. Proportionality is not a ‘nice-to-have’; it is a prerequisite for effectiveness. The EBA has also emphasised the importance of tailoring requirements in a realistic and risk-based manner.

Another practical point is that we are moving towards a triad that must be properly integrated: money laundering, terrorist financing and sanctions evasion.

If these topics continue to be treated organisationally, methodologically and in terms of timing as ‘separate worlds’, gaps will inevitably arise and the result will be audit findings rather than real protective impact.

That’s exactly where his constructive appeal to AMLA comes in.

1. Prioritise the non-financial sector early — not as an afterthought.

2. Provide clear, sector-specific and proportional guidance and publish the RTS/ITS in good time so that obliged entities can implement the measures within the deadlines.

3. Build bridges instead of silos by fostering shared typologies, situational awareness and learning curves between the financial and non-financial sectors.

Tommas Kaplan also brings this perspective to the European level through CEPI, as well as through speeches, keynotes and panel discussions. One such discussion will take place on 29 April at the Anti-Financial Crime Summit in Dublin.