A committee [1] of the Council of Europe (COE) published Guidelines on data protection for the processing of personal data for anti-money laundering/ countering the financing of terrorism purposes, that were announced in July 2023. The guidelines have a peculiar disclaimer:

The opinions expressed in this work are the responsibility of the author(s) and do not necessarily reflect the official policy of the Council of Europe.

It is already clear from the text that the new data-sharing provisions set out in the AMLR have been taken into account. According to page 57 of the publication

These guidelines therefore aim to provide orientation on how to integrate the requirements of the modernised Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data in the area of anti-money laundering/countering the financing of terrorism (AML/ CFT) to provide an appropriate level of data protection while facilitating transborder data flows, and to highlight areas in the AML/CFT context where data protection safeguards should be strengthened.

According to the text, everything the FATF has devised is regarded as the holy grail and is accepted uncritically. This raises the question of whether the committee is truly keeping the fundamental rights of European citizens firmly in mind. In any case, the publication is very vague about the safeguards [8], which may mean that they exist only in theory.

Notes:

[1] Committee of the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data.

[2] E.g. on page 8: “clear policies and procedures“, “clear rules and procedures“and “adequate safeguards for the protection of personal data processed for a given purpose“.