Mirror
Who it’s for
Banks and trade-finance headsThe five-minute brief: what it does, what it refuses, what it costs, where it stands.Supervisors and FIUsThe macro ledger: corridor divergence, measured from signed verdicts.Examiners and auditorsOne signed record, and the checks you run with the network unplugged.EngineersThe operator API, the SDKs and the conformance vectors.Every documentThe protocol, procurement and operations library, in reading order.
ConsoleStart a pilot

DocumentsProcurement and compliance

Mirror under the EU AML package and FATF Recommendation 16: a position paper for counsel

3 min readSource amlr-position.mdsha256 cb864d402d9efc1b…

Status: a position for a bank's counsel to test, not legal advice. Every legal reference below is "as we read it". Confirm it against the current text.

1. What Mirror is, in the terms these texts use#

  • What it does. Mirror lets obliged entities, trade-finance banks, compare what each of them holds about the same trade, without any of them disclosing it to the others or to the operator. Mispricing and phantom shipments show up as disagreement.
  • What it is not. It is not a payment system, not a customer database, and not a reporting channel.
  • Where it works. It supports the entities' own monitoring and investigation of trade-based money laundering, the typology described in the FATF–Egmont Group trade-based money-laundering reports and risk indicators.

2. The AML Regulation, Regulation (EU) 2024/1624 (applies from 10 July 2027)#

  • Information-sharing partnerships. The AMLR provides for partnerships for information sharing among obliged entities (Article 75 of the published text, as we read it), subject to conditions.
    • The conditions include safeguards on what is shared and how it is used, and a data protection impact assessment.
    • Mirror is designed so that what crosses between institutions is the minimum a comparison needs: commitments and a three-state verdict.
  • Mirror's design facts that bear on those conditions:
    • No raw data leaves an institution. It is enforced in code: /cannot raw_value.
    • No filing decision enters the rail. filing_decision is enforced at the door and in the verifier, to keep the tipping-off prohibition intact.
    • Every shared signal names its legal basis, and an unrecognised or missing basis is refused when the operator is configured to require one.
    • Nothing is pushed to, or counted for, a non-party. Counts are released only above a k-anonymity floor.
    • A DPIA pre-fill is published (DPIA).
  • Record keeping. Every verdict is a signed record the entities keep. The verification escrow supports the retention period; the erasure question is addressed in the retention schedule.
  • Outsourcing. The operator is an ICT service provider to each member. The contract schedules are drafted so each promise names its mechanism.

3. The directives#

  • Directive (EU) 2024/1640, the 2024 package's directive, sometimes called AMLD6, addresses supervision and FIUs. Mirror's supervisor seat and offline verification are built for supervisors who want to test a system, not only read about it.
  • Directive (EU) 2018/1673, on combating money laundering by criminal law, often called 6AMLD, defines the offences, including those committed through trade. Mirror produces evidence, signed and verifiable offline; it makes no determination of an offence and holds no filing decision.

4. FATF Recommendation 16: payment transparency#

  • R.16 governs the payment chain. It requires originator and beneficiary information to travel with wire transfers.
  • Mirror is not in the payment path. It carries no originator or beneficiary data, and it cannot: account numbers, IBANs, BICs and payment instructions are forbidden fields in any signed record (settlement_instruction).
  • Where payments meet Mirror:
    • The bander reads the payment leg of a trade from an ISO 20022 pacs.008 / pain.001 message inside the bank. The message carries whatever R.16 requires; Mirror takes only the amount and quantity, which it bands and commits.
    • R.16 compliance therefore stays exactly where it was, with the payment chain. Mirror adds a cross-institution check on whether the payment is consistent with the trade it pays for.

5. What this paper does not settle#

  • Whether a given corridor's arrangement is an AMLR information-sharing partnership, and how its conditions are met in each Member State.
  • The allocation of controller and processor roles.
  • Any national transposition point.

Those are counsel's.

More in Procurement and compliance

PreviousContract schedules: draft clauses for counselNextWhere Mirror sits in a financial-crime programme

Every document, grouped