In Part 3 of this series, Sam and Marie discuss the concerns that EU AML regulators continue to have around crowdfunding platforms - both as customers of financial institutions and as businesses in their own right. They also consider the EBA's assessment of fraud and related financial crime risks that have arisen in 2020 during the COVID pandemic - what should firms have been doing to mitigate those risks? What should regulators have been doing to keep supervising, despite lockdowns 1 -2 and now 3. And despite requiring Business Continuity Programs, could regulators have done more to ensure that firms were "risk ready" and able to adapt to the new normal in which we're currently working?
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