3. #EU #AML PROPOSAL TARGETS PRIVACY PAYMENT INSTRUMENTS AND FREEDOM TOOLS

The current AMLR version specifically targets self-hosted wallets, ignoring their role as vital financial tools as #Bitcoin  for millions of activists facing financial oppression.

Labeled high-risk, self-hosted wallets are now seen as significant money laundering and terrorist financing facilitators. Changes include revisions to Recitals (20) and (21) and the addition of Article (31b) in Charter III, which increases operational and compliance costs, affecting business strategies and client relationships.

The consequences for EU users of self-hosted wallets are serious. Additional compliance checks will complicate, if not block, the conversion of crypto-assets to fiat currency for activists and civil society members already facing financial exclusion. The AMLR overlooks the crucial role of self-hosted wallets in transferring funds to non-democratic or conflict regions, exposing donors and recipients to repression by authoritarian regimes using AML/CFT laws (e.g., in #Belarus, #Kazakhstan, #Turkey).

Smaller clients with self-hosted wallets, viewed as higher risks under Article (31b), may be deprioritized or excluded due to higher transaction compliance costs. This makes them economically unviable for financial institutions, which often favor larger, lower-risk clients for efficiency. The latest AMLR version could effectively ban self-hosted wallets in the EU, significantly impacting the cryptocurrency sector and those vulnerable to oppression.

See our reaction in our Submission: https://en.odfoundation.eu/a/725781,building-true-change-btc-coalition-submission-on-the-eu-proposal-for-a-regulation-on-the-prevention-of-money-laundering-or-terrorist-financing/ https://image.nostr.build/9f0269ec843fd6e399f9e795c266c90af43170334412e3d36b4e6958d43bd2af.jpg https://image.nostr.build/ae5cb7a84266cd45d0789dc4e6abf2d9867e132df47d5b6183bb76bbea46fec4.jpg


In the post-Trialogue version of AMLR proposal Article (41a) “Unwarranted de-risking, non-discrimination and financial inclusion” was deleted.

It was introduced by the European Parliament in 2023 as a result of the #BTC Coalition's human rights advocacy campaign - our testimonials about the financial exclusion in the EU as a result of transnational repression organised by the authoritarian regimes.

Article (41a) was intended to prevent unwarranted de-risking by ensuring that credit and financial institutions have controls and procedures in place to avoid unjustified refusal or termination of business relationships with certain categories of customers. 3/5 https://image.nostr.build/aa06081b518202105a33dca51b3bd213724bda63d34164f9ff43b90fe0db1647.jpg


2. #EU #AML PROPOSAL PROMOTES FINANCIAL EXCLUSION OF VULNERABLE COMMUNITIES
Do you have dual citizenship or are you an immigrant to the EU? Your financial rights are further compromised with the upcoming EU AMLR!

Following the outcomes of the #Trialogue, the AMLR no longer includes regulatory safeguards to prevent unwarranted de-risking, ensure non-discrimination, and promote financial inclusion (Recital (32a) and Article (41a) in Chapter III of the AMLR).

In the post-Trilogue draft of the AMLR, all provisions in Recital (32a) concerning the financial protection of vulnerable communities, including all classes of immigrants (dual citizens, refugees, and asylum seekers, among others) have been deleted.

The previous version of Recital (32a) advocated for due diligence measures based on individual risk assessments, which could prevent blanket denials of service and ensure that measures would be proportionate to the actual risks presented by these specific customer categories.

A post-Trilogue of Recital (32a) is more limited compared to the previous version as it focuses more narrowly only on civil society organisations that conduct charitable or humanitarian work in third countries, without explicitly mentioning the broader range of vulnerable groups.

The post-Trilogue version does not adequately address the nuanced balance between mitigating financial crime risks and ensuring financial inclusion for all vulnerable groups.

4/5 https://image.nostr.build/71aa73d3ada914556baceb865a795044dce6c8901ab516d4eadad422a0f7e205.jpg


Then they fight you. nostr:note1l2j0wve3yhc4vh7yzzdcm4qdqxlw34twsmky3y7f373ag295pfeswx4t8a


How cool this desk clock is!

#nerdminers https://image.nostr.build/05b6b04f60374fb61f7a94144ef9985c63c62e8f6b74e1b805d0f9407beb6166.jpg