According to recent reports in the European media, the European Banking Federation has put before the Committee of European Securities Regulators (CESR) a set of proposed changes to the implementation rules of the Directive, designed to reduce the liability of European banks over the breaches of client confidentiality and financial losses to customers which are likely to be caused by suspicious activity reports.

"It is not reasonable to expect the firm to take on these risks without adequate protection or limits," the Federation's submission to the CESR explained, continuing:

"Furthermore, not providing such a protection will actually undermine the effectiveness of the Directive, since the banks would find themselves in the unfortunate position of choosing between the potential liability risk to the firm of reporting and the regulatory risk of not reporting."

Aditionally, according to the European Banking Federation, financial institutions would like the thresholds for notification to be clarified, as it is currently unclear whether a faint suspicion that wrongdoing is taking place, or the discovery of obvious grounds for suspicion should trigger the reporting requirement.