SIFA has responded to AMLA’s consultation on new regulatory technical standards for customer due diligence (CDD), arguing that the draft rules fail to reflect the specific characteristics of the fund sector and the risk-based approach underpinning the EU AML framework. SIFA stresses that distributors — not fund managers — are the entities with direct customer relationships and responsibility for conducting due diligence. According to SIFA, the proposed rules for collective investment undertakings would fundamentally undermine established fund distribution models without delivering meaningful AML/CFT benefits, while also risking reduced competition and, ultimately, a more limited range of funds available to retail investors.
View the full response: SIFA’s response to the AMLA Consultation paper on Draft RTS under Article 28(1) of Regulation (EU) 2024/1624 (RTS on CDD)