The Joint Committee of the three European Supervisory Authorities (ESAs) began a public consultation Wednesday on standards setting out how financial firms should manage money laundering and terrorist financing risks that may arise from their global operations.

In particular, the consultation addresses issues that arise where a particular country’s domestic laws prevent a firm from adopting policies and procedures on a group-wide basis.

For example, the consultation notes that the sharing of customer information within the firm may conflict with local laws on data protection, or bank secrecy requirements; which could limit a firm’s ability to understand who their customers are.

“Restrictions on obtaining and processing customer data can also facilitate tax crimes, as highlighted in the context of the ‘Panama Papers’,” the Joint Committee says in its announcement.

In these sorts of cases, the ESAs stress that financial institutions must take steps to handle the resulting risk of being exposed to money laundering, or bring used as a conduit for terrorist financing.

These steps include:

> obtaining consent from customers to overcome restrictions on the ability to share their data;

> carrying out enhanced reviews to ensure that the firm is adequately managing these risks; and

> restricting the ability of the firm to rely on the due diligence carried out in countries that have laws that may hinder compliance with firm-wide policies and procedures to guard against money laundering risks.

The deadline for the consultation is July 11.

The ESAs are planning to hold a public hearing on the draft standards for June 23 in London.