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Niels Skovmand Rasmussen

The article explores the historic and contemporary development of the EU supervisory framework in Anti-Money Laundering/Combating the Financing of Terrorism (AML/CTF). First, it makes the key argument that the development has an incremental or evolutionary nature where the operational capacity of the former 3L3 committees was gradually expanded in response to external shocks; such as the global financial crisis of 2007-2008. However, this development path has not allowed the ESAs to address a number of fundamental challenges in the area of AML/CTF. The article then analyzes the most important changes brought by the amending Regulation (EU) 2019/2175 to the intervention powers, governance arrangements and funding model of the ESAs. This includes the brand-new power to request a national competent authority to investigate possible breaches of Union law by a financial sector operator. On this basis, the article evaluates whether the amending Regulations in fact address the historic challenges of the EU supervisory framework in AML/CTF.

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Troels Michael Lilja og Niels Skovmand Rasmussen

Thearticlepresents a concluding remark in relation to the following articles: 1. Initial Coin Offerings – Are tokens transferable securities?, 2. The ESAs’ Union Strategic Supervisory Priorities: A new effective tool to promote supervisory convergence in Europe?, 3. The New Role of the European Banking Authority in AML/CTF: Strong Agency Powers and Sectoral Legislation Without Direct Effect?, 4. The principles guiding the ECB’s enforcement and sanctioning powers, and 5. Direct financial supervision in the EU and financial stability published in this and the previous issue of NTS regarding the enforcement of the Single Rulebook.



. Associate Professor, CBS LAW, Copenhagen Business School.


. Associate Professor, University of Southern Denmark.