FATF AML/CFT and data protection experts' seminar

Brussels, 24 March 2014. The Financial Action Task Force (FATF), in coordination with the European Commission, organised a one day seminar on data protection and anti-money laundering/combatting the financing of terrorism (AML/CFT) with the participation of data protection, AML/CFT and private sector experts. The meeting was opened by the , chaired by the Co-Chairs of the FATF Policy Development Group and closed by the European Commission (DG MARKT), who also hosted the meeting.

The aim of this seminar was to exchange views, map commonalities, including on existing good practices, and to foster a dialogue between all relevant experts at the national, supranational and international level. 

Data protection and AML/CFT requirements both aim to protect citizens against abuse and, as participants to the seminar stressed, it is important that both sets of requirements are implemented in a consistent manner. The following topics were also discussed:

• Participants recognised that both AML/CFT and data protection requirements serve important objectives which are not inherently mutually exclusive. General data protection requirements, if not tailored to the specificities of the fight against financial crime, can impede on the effective and risk-based implementation of AML/CFT requirements. In particular, participants noted that inconsistent legal frameworks across different jurisdictions create implementation challenges, particularly for the private sector.
• Sharing examples of enforcement actions which have been taken in the AML/CFT and data protection context can be a useful way to enhance the understanding of what implementation issues have arisen in practice. Where such issues do arise, further clarity on how to comply with both sets of requirements is welcome.
• While participants discussed the application of the general data protection rules and how this may create challenges for the effective and risk based implementation of AML/CFT requirements, participants also heard some concrete best practices of how countries are achieving consistency in practice.
• Participants stressed the importance of a continuing dialogue between AML/CFT and data protection authorities.
• The FATF will remain vigilant that AML/CFT measures are implemented effectively in all jurisdictions.

The meeting heard presentations from Belgium, Canada, the European Commission, the European Data Protection Supervisor, the European Union Data Protecting Working Party (Art 29), Spain, the United States, GE Capital, Western Union, and the Wolfsberg Group of Banks. The full list of the 56 participating jurisdictions, organisations and private sector bodies is below.

Financial Action Task Force
24 March 2014

Participating jurisdictions, organisations and private sector bodies