The upcoming european anti-money laundering and countering the financing of terrorism legislative package: ; lessons to learn from the Banking Union on the (long) road towards harmonization.

Since it first started raising the eyebrows of regulators in the 80s, prevention of ML/TF has consumed a growing amount of supervisory resources and became subject to increasingly detailed and burdensome regulatory frameworks. In the EU, following a string of prominent cases of money laundering involving European institutions, the Commission proposed a drastic overhaul of the AML/CFT framework that will reshape the supervisory architecture and regulatory approach. The key aspects of novelty concern the creation of an EU-level AML/CFT supervisory authority and the development of an AML/CFT Single Rulebook. These changes were inspired by the similar process of regulatory harmonization and (partial) transfer of supervisory tasks to the supranational level that took place in the prudential sphere after the global financial crisis. The example drawn from the SSM and the prudential Single Rulebook can help shed light on the strengths and areas for improvement of the Commission’s AML Package and on its ability to address the shortcomings of the current AML/CFT framework.