Joint Committee publishes report on the implementation of anti-money laundering and counter-terrorist financing requirements for e-money in the EU

07 December 2012

The Joint Committee of the European Supervisory Authorities (EBA, ESMA and EIOPA) has today published a report on the application of AML/CTF obligations to, and the AML/CTF supervision of e-money issuers, agents and distributors in Europe.

The report:

  • provides an overview of Member States' implementation of EU anti-money laundering (AML) and counter-terrorist financing (CTF) requirements in relation to the issuance, distribution and redemption of electronic money;
  • identifies areas where differences in the national implementation of European legislation could affect the integrity of the AML/CTF regime; and
  • recommends action by the European Commission to address inadequacies in the legislation and its implementation during the current revisions of the 2nd E-money Directive and 3rd Money Laundering Directive.

Differences in implementation

The report reveals that significant differences existedin the national implementation of the 2nd E-Money Directive (2nd EMD) and in the application of AML/CTF legislation to e-money issuers, their agents and distributors. 

These differences are caused by inadequate or ambiguous provisions in the 2nd EMD and 3rd Money Laundering Directive, including such issues as:


  • the definition of the point in time where e-money is issued;
  • the definition of e-money agents and distributors;
  • the application of passporting rules and guidelines to e-money entities; and
  • the distribution of powers between home and host AML/CTF supervisors.