supervisory tools to use could be employed early on to tackle fragmentation across different jurisdictions. this is understandable for a few reasons. first, one of the drivers for a single central aml authority was the divergent approaches across member states. secondly, the quickest path to bring about supervisory convergence across the member states would be to prescribe a more rigid approach. thirdly, in the short term it may be seen as more expedient to approach risks in firms not directly supervised by amla. 3 / 6 bis - central bankers'speeches this would be a mistake as the danger with this approach is that we inadvertently introduce a rules - based approach to how we supervise that could equate to a tick - box approach, something that will mean we miss the risks, reduce the effectiveness of the system and goes against the intention of the global aml system. so while supervisory convergence and common methodologies, practices and approaches are necessary to improve the framework, we need to avoid a " one size fits all " approach. the second issue from an effectiveness and efficiency perspective is that amla should be outcomes - focused when implementing its risk - based approach. a strong and robust supervisory framework will need to be designed that has clear processes. however, it is important that we learn the lessons in other regulatory and supervisory organisations where process can sometimes get in the way of effectiveness. it goes to my previous point in that we need to have clear rules and guidance, but we must be pragmatic and flexible at times to ensure that we can achieve the right outcomes. we must not lose sight of outcomes and outputs not being the same thing. a third issue is that amla's risk - based approach must look at not only the risks today, but also the emerging risks into the longer term. this means amla will need to build in a way that allows it to be looking at the risks today but also be forward - looking and agile. this will allow it to pivot in its approach and focus when necessary to keep pace with change. again, what aids this is not relying too heavily on prescription or process driven approaches but more on flexible approaches that allows one to follow the risks, wherever they might lead. finally, amla should be clear and confident in its approach allowing it to leverage off the support it has from policy - makers, national supervisors and other regulatory and supervisory authorities in discharging its mandate. as a new authority with a wide mandate created from scratch, it will need to

, it will have to work in a spirit of cooperation and collaboration to build a common supervisory culture with national supervisors to ensure that firms not directly supervised are complying with their aml / cft obligations. amla must foster with the ncas an effective and responsive risk culture and be prepared to step and take swift action ncas fail to meet its expectations in mitigating ml / tf risks. amla should not attempt to create everything from scratch and should work off existing initiatives4. for example, it should both leverage off existing and foster new relationships with law enforcement across the eu and with other eu institutions, which will be critical to its success. conclusion in truth, amla's success is not dependent on any single factor. the drivers of success are multifaceted. a harmonised rulebook, overseen by a single supervisor that raises standards and delivers increased alignment and cooperation across the regulatory landscape is certainly a good starting point. history has taught us that no system is entirely'future proof'and vigilance, agility and innovation are constantly required. since the first aml directive was enacted in 1991, the legislative landscape has continuously developed in line with our awareness and understanding of the ml / tf risks. amla will need to ensure that this process of evolution continues. 5 / 6 bis - central bankers'speeches i greatly look forward to amla's progress and the central bank of ireland will play our part in meeting our shared objectives. thank you. 1 with thanks to jillian fleming, paul o'brien and tony cahalan for their assistance preparing these remarks 2 some of these issues and considerations have been explored recently by the imf. see https : / / www. imf. org / en / blogs / articles / 2023 / 09 / 18 / financial - stability - needs - supervisorswith - the - ability - and - will - to - act 3 the regulatory craft : controlling risks, solving problems, and managing compliance by malcom k. sparrow 4 such as the european banking authority's guidelines on cooperation and information exchange between prudential supervisors, aml supervisors and financial intelligence units ( fius ). 6 / 6 bis - central bankers'speeches