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Hello Jennifer,
I would like to thank you for putting together the captioned article which provides an excellent mapping of the evolution of EU’s AML framework into an all encompassing Financial Crimes framework which as you rightly point out promotes a basis for a unified set of rules across the member states with which EU AMLA, the direct supervisor can monitor the applications of Fin/Crime rules across the EU.
Given that the UK & the US heavily influence activity in the EU, is there any research that you are aware of that has been undertaken that provides a similar evolution of the Financial Crimes framework in these two jurisdictions? Granted it is early days yet for the UK but is the trend that of conformity with the EU’s evolution or do you see a divergence?
US’ approach is interesting especially in light of the advent of virtual assets. Whereby it appears that the EU is bringing virtual assets in-scope under the Funds Transfer Regulation whereas the US is differentiating these assets with a view to including them under different regulatory authorities.
Mohmud Mohamed
CAMs