The Institute welcomes the publication by the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (“AMLA”) of the Consultation Paper on Draft Regulatory Technical Standards on criteria for business relationships, occasional transactions and linked transactions as well as lower thresholds under Article 19(9) of the AMLR, and the opportunity to provide responses on behalf of its members to the questions set out in the paper.

The views expressed in this letter reflect those of the Institute as a professional body for compliance professionals in consultation with a sub-section of its members representing a range of financial services industry sectors.