The IIF submitted comments to the European Banking Authority (EBA) on their recent consultation on money laundering (ML) and terrorist financing (TF) risk factor guidelines. The consultation updates the EU guidelines in order to address new issues and increase continuity in EU wide adoption. The IIF comments reflect a focus on achieving a greater balance between the Risk Based Approach and EU wide harmonization. It addresses the need for further alignment with FATF standards and offers specific technical feedback on various areas including Correspondent Banking, rules for Politically Exposed Persons, rules for payment services providers and the use of technology standards.