Insurance Europe responded to the EBA’s consultation on EU anti‑money laundering Regulatory Technical Standards, supporting a harmonized, data‑driven risk assessment but urging proportionality. They advocate for minimal, targeted data collection, reasonable transition periods, and revised data points to ease burdens, particularly for low‑risk products. The federation opposes excessive customer data requirements, supports remote identification, and proposes event‑driven updates for low‑risk life insurance and simplified due diligence for pensions and pure risk policies. Insurance Europe commits to collaborating for an effective, risk‑based AML/CFT framework.