Study on the interconnection of centralised automated mechanisms in the European Economic Area : final report

The European Commission's Directorate General for Financial Services, Financial Stability and Capital Markets Union (DG FISMA, the Contracting Authority) contracted this study, performed by Fincons and BR-AG, with the primary objective to examine the technical and IT solutions to interconnect the centralised automated mechanisms (hereafter CAMs) established by the EEA Member States pursuant to Article 32a of the AMLD0F1. The final text of the new AMLD1F2 lays down a requirement to interconnect those CAMs and to give FIUs, AMLA and AML/CFT supervisory authorities access to the Bank Account Registers Interconnection System (BARIS). Furthermore, another legislative instrument amending Directive 2019/11533 provides designated competent authorities with the power to directly access BARIS for the purposes of preventing, detecting, investigating and prosecuting serious crimes or supporting a criminal investigation concerning a serious criminal offence. Therefore, the need for interconnection of CAMs across EU Member States aligns with the objectives of the new AMLD, as well as with amendments to Directive 2019/11532F. Furthermore, the European Commission's (hereinafter referred to as 'Commission') 2019 report on the interconnection of CAMs confirmed the technical feasibility of interconnecting those mechanisms3F4. The study has the following objectives: (i) to analyse the technical specificities of the operational CAMs set up across the EEA Member States, (ii) to assess various available technical and IT solutions to interconnect the CAMs by means of BARIS, and (iii) to advise the Contracting Authority on the most appropriate, effective, and cost-efficient technical and IT solution to interconnect the CAMs by means of BARIS.