The European FinTech Association (EFA) calls for:

1. EU-wide harmonization of digital identification methods
   • Minimum set of qualified methods and criteria for the digital identification of customers need to be accepted EU-wide
   • Facilitating third party reliance via mutual recognition of AML-compliant identification procedures across EU member states is key for safe and convenient KYC procedures. The design of applicable “suitable safeguards” as described by recital 35 AMLD should be conclusive on the European level
2. Transsectoral approach for mutual recognition of ID-levels between different regulated sectors
   • “eIDAS” Regulation (EU) No. 910/2014 and use of Qualified electronic signatures (QES) could provide for identification standard that facilitates interoperability of digital identities across industry sectors, including banking, health, mobility, public and telecommunication
3. More regulatory guidance regarding application of AML rules to new regulated services, e.g. via circulars or guidelines
4. Re-consideration of AML Rules for Account Information Service and Payment Initiation Service Providers
5. Harmonization of Suspicious Transaction Reporting and improving the cooperation between the FIUs according to Art. 52, 53 AMLD

You can find the full EFA’s position here.