Invest Europe

Response to EBA Consultation Paper on Response to the European Commission’s Call for Advice new AMLA mandates

Positions & consultation responses

06 Jun 2025

Private equity (PE), venture capital (VC), and infrastructure managers operate under a model setting that is distinctly apart from deposit-taking or high-frequency transactional institutions. As such, many of the more granular provisions in the RTS — including those concerning customers’ transactional behaviour, real-time remote identification, and direct engagement with natural persons — are of very limited applicability for the entire PE-, Infrastructure investment and VC industry. We encourage EBA to recognise these distinctions in application and guidance, in line with the proportionality principle.