March 1st, the European Banking Authority (EBA) published its final guidelines on money laundering and terrorist financing (ML/TF) risks factors. Drawing on information provided by competent authorities (CAs), among others, the EBA opinion examines diverse risks and proposals for addressing these risks, including:

• Risks associated with virtual currencies

• Risks associated with the provision of financial products and services through FinTech firms

• Risks arising from weaknesses in CFT systems and controls

• Risks arising from de-risking

• Risks arising from supervisory divergence

• Risks associated with crowdfunding platforms

• Risks arising from divergent approaches to tackling tax-related crimes

• Risks arising from the COVID-19 pandemic

The EBA outlines that in accordance with article 14(5) AMLD, firms need to apply customer due diligence measures to new and also existing customers at appropriate times on a risk sensitive basis, or when circumstances change. Thus, the revised Guidelines is applicable to new customers as well as to existing customers.