A Commentary from RUSI on 11 June says that in the EU-UK discussions the usual areas of disagreement are raised: access to Britain’s fishing grounds, the requirements of a level playing field agreement, regulations over state aid etc.  However, it notes that the EU’s lead negotiator – raises the question of AML/CFT in each update, and not with an air of optimism.  It says that, at least as far as the EU is concerned, the UK’s ambition on AML is being brought into question.  It notes that the UK can argue that it needs not fully commit to implementing current or future AML/CFT Directives, as such a commitment exists, in effect, in commitment to FATF standards, but then says FATF establishes baseline levels, which may be insufficient.  Finally it raises 2 related questions – the future relationship on law enforcement and judicial cooperation and data exchange, an area where the approach in the UK and the EU is often divergent; and potential inefficiencies and difficulties for businesses should EU and UK requirements diverge.


If you would like to say thanks by making a small contribution, in case I need to upgrade or replace my computers and other paraphernalia, I have a page at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Google photo

You are commenting using your Google account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s