Posteitaliane. - Comments by Poste Italiane S.p.A. - Divisione BancoPosta
|
|
- Jewel Neal
- 5 years ago
- Views:
Transcription
1 Posteitaliane Divisione BancoPosta Invitation for public comment on DG Internal Market services Working Document in relation to the Directive of the European Parliament and of the Council on the prevention of the use of the financial system for the purpose of money laundering and terrorist financing (Third Directive) - Comments by Poste Italiane S.p.A. - Rome, 20 October 2005
2 Invitation for public comment on DG Internal Market services Working Document in relation to the Directive of the European Parliament and of the Council on the prevention of the use of the financial system for the purpose of money laundering and terrorist financing (Third Directive) - Comments by Poste Italiane S.p.A. - CONTENTS: 1. Introduction General Remarks The risk-based approach and the definition of technical criteria...3 Question Questions 2, 4 and The definition of Politically Exposed Persons (PEPs) The application of Article 40 (4) of the Third Directive Introduction Poste Italiane S.p.A. ( Poste Italiane ) welcomes the opportunity to submit its comments on DG Internal Market services Working Document related to Chapter VI (Implementing Measures) of the Directive of the European Parliament and of the Council on the prevention of the use of the financial system for the purpose of money laundering and terrorist financing (the Third Directive ). In our view, the implementing measures complete the legal framework created by the Third Directive and clarification of the technical aspects is necessary to ensure its effective and consistent implementation. In this document, Poste Italiane will present its position on the criteria to be followed in the implementation of the Third Directive and provide its comments on the three issues raised in the working document, namely: 1) The definition of technical criteria for the implementation of Article 40 (1) b of the Third Directive; 2) The technical aspects of the definition of Politically Exposed Persons (PEPs); 3) The application of Article 40 (4) of the Third Directive.
3 2. General Remarks The Third Directive requires the institutions and persons to which it applies, including credit and financial institutions, to contribute to the prevention of the use of the financial system for the purpose of money laundering and terrorist financing. These institutions and persons should cooperate with public authorities with a view to preserving the integrity of the system. Poste Italiane is aware of the importance of anti-money laundering and antiterrorist financing regulations and believes that the synergy between the private sector and public authorities is remarkably valuable in order to achieve the aims of the Third Directive. Nonetheless, Poste Italiane would like to draw attention to the fact that the Third Directive requires private parties to comply with quite a lot of obligations and there are concerns that, unless a certain degree of flexibility is foreseen, the burden and cost of compliance could undermine the smooth functioning of the system put in place by the Third Directive. With this in mind, from a general perspective, Poste Italiane would welcome that Articles 40 (1) (b) and 40 (1) (d) be implemented in such a way that the burdens on credit and financial institutions are always proportionate to the risks connected to the nature of a client or of a transaction. 3. The risk-based approach and the definition of technical criteria In Poste Italiane s view, the Commission should, where possible, define technical criteria in broad terms or at least - require their non-cumulative fulfillment. This would allow provisions of the Third Directive such as Articles 2 (2), 11 (2) and 11 (5) to produce their useful effect, while reducing the burden on private parties to the minimum, so that resources can be invested to address situations where the risk of money laundering or terrorist financing is higher. Indeed, as Recital 43 of the Third Directive states, the clarification of the technical aspects of the rules lay down in the Directive itself may be necessary to ensure an effective and sufficiently consistent implementation of the directive, taking into account the different financial instruments, profession and risks in the different member States and the technical developments in the fight against money laundering. The task of the Commission, according to the same provision, is to define certain criteria for identifying low and high risk situations in which simplified due diligence could suffice or enhanced due diligence would be appropriate, provided that the essential elements of the Third Directive and the principles thereof are respected. When implementing Articles 2 (2), 11 (2) and 11 (5), the Commission should therefore provide sufficient guidance to the institutions and persons to which
4 the Third Directive applies, safeguarding the possibility of graduating duediligence measures in relation to the concrete risk. Consistently with these principles, Poste Italiane addresses below some of the questions raised by the Working Document. Question 1 In Poste Italiane s view, the application of the risk-based approach in relation to the normal CDD procedures should be retained as the normal tool to deal with low risk customers and products/transaction. In this respect, Article 8 (2) of the Third Directive provides for a satisfactory degree of flexibility while, at the same time, guaranteeing that financial and credit institutions carefully assess the risk connected with each transaction. It is our opinion that the risk-based approach should be retained, as opposed to application of a case-by-case approach implying the need of adopting implementing measures that, while increasing the procedural burdens, may not adapt quickly enough to the evolution of business practices. Poste Italiane would also recommend that non-binding guidelines be adopted, within a certain period from the transposition of the Third Directive, to orientate the action of the institutions and persons to which the Directive applies, in the light of the concrete experience and information collected on money laundering activities. Questions 2, 4 and 6 Following the approach above, it appears that the technical criteria proposed by the Commission in paragraphs 3.2, 3.3 and 4 of the Working Document were these to be applied cumulatively would leave very little room for the application of simplified CDD procedures, and would deprive the institutions and persons to which the Third Directive applies of any margin of appreciation of the risk created by each transaction. In relation to question No. 2, for instance, as the Commission acknowledges, the first set of cumulative criteria listed in paragraph 3.2 would hardly apply to any entities apart from credit and financial institutions which are already subject to simplified CDD. In Poste Italiane s view, the non-cumulative application of the same criteria would be sufficient to significantly reduce the necessity of a normal CDD: once the identity of customer is publicly available, transparent and certain (criterion 2) and/or the only material source of income is known, stable and of impeccable nature (criterion 6), it would be reasonable to consider that risks of money laundering and terrorist financing are low.
5 Again, as for question No.4, Poste Italiane would consider that the criteria related to products and transactions foreseen in paragraph 3.3 would be sufficient to allow the application of simplified CDD procedures, even if these were non-cumulative. When, for instance, a financial transaction is imposed by legislation as under criterion 1 risks of money laundering or terrorist financing are virtually excluded, as the purpose of the transaction is to fulfil a legal obligation, and the persons or entities involved have no choice as whether to carry out the transaction. Regarding question No. 6, in Poste Italiane s opinion, the criteria proposed by the Commission in paragraph 4 would force credit and financial institutions to carry out a rather deep and complex assessment, which would be in some respect as burdensome as a CDD process: the entities concerned should be able to define the total turnover of their customers, estimate the weight of financial activities in relative and absolute terms and ascertain that the financial activities are directly related to the main activity of the person. This preliminary assessment should be done in respect to a relevant number of customers and transactions, only to establish whether the Third Directive would be applicable to their specific case. Again, it would be preferable that the Commission define broader and simpler criteria in order to establish whether a legal or natural person is engaging in a financial activity on an occasional or very limited basis. Poste Italiane would recommend that the Commission seek to define simpler, broader and non-cumulative criteria, in order to allow financial and credit institutions to apply simplified CDD to low-risk transactions, focusing resources on situations where the risk of money laundering and terrorist financing is higher. 4. The definition of Politically Exposed Persons (PEPs) Regarding the definition of PEPs, Poste Italiane shares the Commission s view that a clarification of the definition is needed and that nevertheless it is recommendable that Member States preserve a sufficient degree of flexibility in implementing the Third Directive in this respect. Accordingly, Poste Italiane believes that the definition of interpretative criteria for the three main parts of the definition is a more appropriate solution than the simple drafting of a close list of categories of persons. The latter may indeed be excessively rigid, considering that the Third Directive should apply to 25 Member States with dissimilar institutional systems and that the risk of money laundering may vary with time. In its implementing measures, the Commission should rather precisely define the notions of immediate family members and of persons known to be associates of the PEPs, which will not diverge greatly from one Member
6 State to the other. Instead, regarding the definition of prominent public functions, it should limit itself to list certain minimal requirement. Also, to the benefit of legal certainty, Poste Italiane would strongly recommend that the Commission define the time limit following which a person who held public functions should still no longer be considered as being a PEP. Finally, Poste Italiane agrees with the Commission s proposal of preparing a guidelines paper in cooperation with Member States. The Commission should clearly define the meaning of the three parts of the definition of PEPs. However, Member States should have a margin of discretion in defining what prominent public functions are in their institutional system. A clear timeframe for the purpose of the application of PEP definition to persons no longer holding prominent public functions should also be defined. 5. The application of Article 40 (4) of the Third Directive Poste Italiane is aware of the importance that the Third Directive be applied not only to transactions that take place within the EU, but also to operations that are linked to a third country. In this respect, Poste Italiane would encourage the Commission to create a system whereby information on anti-money laundering measures adopted in third countries circulate among credit and financial institutions. This would help the institutions concerned with assessing the risks connected with a transaction. ********** Please note that Poste Italiane would be happy to expand on any of the points above. We also have no objection to our comments being made available to the public. Any question regarding these comments may be addressed to: Alessandra Fratini (a.fratini@oconnor.be) Claudio Bertuccelli (bertuccelc@posteitaliane.it)
DOC 0998/05 Brussels, 24 October European Savings Banks Group (ESBG)
EUROPEAN SAVINGS BANKS GROUP GROUPEMENT EUROPEEN DES CAISSES D EPARGNE EUROPÄISCHE SPARKASSENVEREINIGUNG DOC 0998/05 Brussels, 24 October 2005 V 1.1 CAL European Savings Banks Group (ESBG) Comments on
More informationEuropean Commission s Working Document on Implementing Measures under the Third Money Laundering Directive Response of the Law Society
European Commission s Working Document on Implementing Measures under the Third Money Laundering Directive Response of the Law Society 1 European Commission's Working Document on Implementing Measures
More informationFINAL DRAFT RTS UNDER ARTICLE 45(6) OF DIRECTIVE (EU) 2015/849 JC /12/2017. Final Report
JC 2017 25 06/12/2017 Final Report On Draft Joint Regulatory Technical Standards on the measures credit institutions and financial institutions shall take to mitigate the risk of money laundering and terrorist
More informationEurofinas is entered into the European Transparency Register of Interest Representatives with ID n
Eurofinas observations on the Commission s Proposal for a Directive on the prevention of the use of the financial system for the purpose of money laundering and terrorist financing (COM(2013) 45 final)
More informationTo: Mr Bill Newton Dunn Rapporteur of the European Parliament Committee on Development
To: Mr Bill Newton Dunn Rapporteur of the European Parliament Committee on Development Mr Krišjānis Kariņš Rapporteur of the European Parliament Committee on Economic and Monetary Affairs Email: bill.newtondunn@europarl.europa.eu
More informationCentral Bank of The Bahamas PUBLIC CONSULTATION
Central Bank of The Bahamas PUBLIC CONSULTATION Proposed Revisions to the Guidelines on the Prevention of Money Laundering & Countering the Financing of Terrorism I. INTRODUCTION 1. The Central Bank of
More information4th Anti-Money Laundering Directive and 2d Fund Transfers Regulation- General overview and impact on payments
4th Anti-Money Laundering Directive and 2d Fund Transfers Regulation- General overview and impact on payments Payment systems market expert group Brussels, 3 December 2015 European Commission DG Justice
More informationECB-PUBLIC OPINION OF THE EUROPEAN CENTRAL BANK. of 30 May on the limitation of cash payments (CON/2017/20)
EN ECB-PUBLIC OPINION OF THE EUROPEAN CENTRAL BANK of 30 May 2017 on the limitation of cash payments (CON/2017/20) Introduction and legal basis On 3 April 2017 the European Central Bank (ECB) received
More informationon the OECD Public Discussion Draft (BEPS Actions 8-10) Revised Guidance on Profit Splits
Opinion Statement FC 12/2016 on the OECD Public Discussion Draft (BEPS Actions 8-10) Revised Guidance on Profit Splits Prepared by the CFE Fiscal Committee Submitted to the OECD in September 2016 The CFE
More informationJC /05/2017. Final Report
JC 2017 08 30/05/2017 Final Report On Joint draft regulatory technical standards on the criteria for determining the circumstances in which the appointment of a central contact point pursuant to Article
More informationLetter of formal notice Assessment of acquisitions and increase of holdings in the financial sector
Brussels, 15 March 2017 Case No 77973 Document No: 817335 Decision No: 046/16/COL The Norwegian Ministry of Finance Financial Markets Department Postbox 8008 Dep N-0030 Oslo Norway Dear Sir or Madam, Subject:
More informationConsultation Paper Indirect clearing arrangements under EMIR and MiFIR
Consultation Paper Indirect clearing arrangements under EMIR and MiFIR 5 November 2015 ESMA/2015/1628 Responding to this paper The European Securities and Markets Authority (ESMA) invites responses to
More informationDear Chairman, dear Members of the TAX3 Special Committee,
INTRODUCTORY STATEMENT OF PIERS HABEN, EBA DIRECTOR, AT THE TAX 3 PUBLIC HEARING Introductory statement of the EBA Director of Banking Markets, Innovation and Consumers before the Special Committee on
More informationOfficial Journal of the European Union L 214/29
4.8.2006 Official Journal of the European Union L 214/29 COMMISSION DIRECTIVE 2006/70/EC of 1 August 2006 laying down implementing measures for Directive 2005/60/EC of the European Parliament and of the
More informationTHE ANTI-MONEY-LAUNDERING DIRECTIVE IMPLEMENTATION GROUP OF THE LEGAL PRACTICE DIVISION OF THE INTERNATIONAL BAR ASSOCIATION RESPONSE TO:
THE ANTI-MONEY-LAUNDERING DIRECTIVE IMPLEMENTATION GROUP OF THE LEGAL PRACTICE DIVISION OF THE INTERNATIONAL BAR ASSOCIATION RESPONSE TO: THE WORKING DOCUMENT IN RELATION TO THE DIRECTIVE OF THE EUROPEAN
More informationCEEP OPINION ON THE PROPOSAL FOR A DIRECTIVE ON THE ACTIVITIES AND SUPERVISION OF INSTITUTIONS FOR OCCUPATIONAL RETIREMENT PROVISION (IORP II)
Brussels, 10 November 2014 Opinion.07 THE ACTIVITIES AND SUPERVISION OF INSTITUTIONS FOR OCCUPATIONAL RETIREMENT PROVISION (IORP II) Executive summary In its initial press release published on 28 March
More informationMoney Laundering Regulations 2017
Money Laundering Regulations 2017 A public consultation issued by HM Treasury Comments from April 2017 Ref: TECH-CDR-1535 (the Association of Chartered Certified Accountants) is the global body for professional
More informationEFAMA s comments on ESMA s Consultation Paper Guidelines on certain aspects of the MiFID II suitability requirements [ESMA ]
EFAMA s comments on ESMA s Consultation Paper Guidelines on certain aspects of the MiFID II suitability requirements [ESMA35-43-748] General Comments EFAMA 1 welcomes provision by ESMA of guidelines on
More informationCOMMISSION DELEGATED REGULATION (EU) /... of XXX
EUROPEAN COMMISSION Brussels, XXX [ ](2017) XXX draft COMMISSION DELEGATED REGULATION (EU) /... of XXX amending Delegated Regulation (EU) 2016/1675 supplementing Directive (EU) 2015/849 of the European
More informationCOMMISSION DELEGATED REGULATION (EU) /... of
EUROPEAN COMMISSION Brussels, 13.12.2017 C(2017) 8320 final COMMISSION DELEGATED REGULATION (EU) /... of 13.12.2017 amending Delegated Regulation (EU) 2016/1675 supplementing Directive (EU) 2015/849 of
More informationRe: IAASB Invitation to Comment Improving the Auditor s Report
The Chair Date: 20 December 2012 ESMA/2012/ESMA/849 Arnold Schilder IAASB Chairman 545 Fifth Avenue, 14th Floor New York 10017 United States of America Re: IAASB Invitation to Comment Improving the Auditor
More informationANTI-MONEY LAUNDERING AND COUNTER-TERRORISM FINANCING POLICY IFD - INSTITUIÇÃO FINANCEIRA DE DESENVOLVIMENTO, S.A.
IFD - INSTITUIÇÃO FINANCEIRA DE DESENVOLVIMENTO, S.A. June 2018 CONTENTS 1. INSTITUTIONAL INFORMATION... 3 2. INTRODUCTION... 4 3. MONEY LAUNDERING... 5 4. TERRORISM FINANCING... 6 5. MAIN PRINCIPLES...
More informationEUROPEAN CENTRAL BANK
28.1.2009 C 21/1 I (Resolutions, recommendations and opinions) OPINIONS EUROPEAN CTRAL BANK OPINION OF THE EUROPEAN CTRAL BANK of 6 January 2009 on a proposal for a Regulation of the European Parliament
More informationBIPAR Fédération européenne des intermédiaires d'assurances European Federation of Insurance and Investment Intermediaries
BIPAR Fédération européenne des intermédiaires d'assurances European Federation of Insurance and Investment Intermediaries Avenue Albert-Elisabeth 40, B-1200 Bruxelles Tel: +32/2/735 60 48 Fax: +32/2/732
More informationTHE THIRD EU DIRECTIVE ON MONEY LAUNDERING AND TERRORIST FINANCING
11 THE THIRD EU DIRECTIVE ON MONEY LAUNDERING AND TERRORIST FINANCING Ján Vyhnálik, Izabela Fendeková National Bank of Slovakia In May of this year, the European Parliament and Council adopted the Directive
More informationCOMMUNICATION FROM THE COMMISSION. Common principles on national fiscal correction mechanisms
EUROPEAN COMMISSION Brussels, 20.6.2012 COM(2012) 342 final COMMUNICATION FROM THE COMMISSION Common principles on national fiscal correction mechanisms EN EN COMMUNICATION FROM THE COMMISSION Common principles
More informationAMF Position-recommendation
AMF Position-recommendation 2013-23 Guidelines on the notion of politically exposed persons in connection with anti-money laundering and counter-terrorist financing Reference texts: Articles L. 561-10
More informationBrussels, COM(2018) 767 final
EUROPEAN COMMISSION Brussels, 28.11.2018 COM(2018) 767 final COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE EUROPEAN COUNCIL, THE COUNCIL, THE EUROPEAN CENTRAL BANK, THE EUROPEAN ECONOMIC
More informationComments on EBA Draft Regulatory Technical Standards
Comments on EBA Draft Regulatory Technical Standards On the homogeneity of the underlying exposures in securitisation under Art. 20(14) and 24(21) of Regulation (EU) 2017/2402 of the European Parliament
More informationII part INDEX. A. Introduction... Page 1
International and European Affairs BANCA INTESA S RESPONSE TO CESR S FIRST CONSULTATION ON ITS DRAFT ADVICE TO THE EUROPEAN COMMISSION FOR IMPLEMENTING LEGISLATION UNDER DIRECTIVE 39/2004 II part INDEX
More information2 EFAMA's reply to ESMA's Consultation on the revised Transparency Directive
EFAMA Reply to the Draft Regulatory Technical Standards on major shareholdings and indicative list of financial instruments subject to notification requirements under the revised Transparency Directive
More informationFG16/6 Payment Accounts Regulations 2015
Finalised guidance FG16/6 Payment Accounts Regulations 2015 Definition of a payment account August 2016 Introduction 1. This guidance is given under regulation 40 of the Payment Accounts Regulations 2015
More informationOfficial Journal of the European Union
L 3/16 COMMISSION IMPLEMTING REGULATION (EU) 2016/7 of 5 January 2016 establishing the standard form for the European Single Procurement Document (Text with EEA relevance) THE EUROPEAN COMMISSION, Having
More informationCouncil of the European Union Brussels, 20 June 2018 (OR. en)
Council of the European Union Brussels, 20 June 2018 (OR. en) Interinstitutional Files: 2017/0251 (CNS) 2017/0249 (NLE) 2017/0248 (CNS) 10335/18 FISC 266 ECOFIN 638 NOTE From: To: No. Cion doc.: Subject:
More informationCOMMISSION OF THE EUROPEAN COMMUNITIES. Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
EN EN EN COMMISSION OF THE EUROPEAN COMMUNITIES Brussels, 13.10.2008 COM(2008) 640 final 2008/0194 (COD) Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on cross-border payments
More informationto the CESR s technical advice on the European commission on the level 2 measures related to the UCITS management company passport CESR/09.
Paris, 10 th September 2009 Response of the French Banking Federation (FBF- Fédération Bancaire Française) and French Association of Securities Professionals (AFTI - Association Française des Professionnels
More informationThis document is meant purely as a documentation tool and the institutions do not assume any liability for its contents
2006L0049 EN 04.01.2011 004.001 1 This document is meant purely as a documentation tool and the institutions do not assume any liability for its contents B DIRECTIVE 2006/49/EC OF THE EUROPEAN PARLIAMENT
More informationThe fifth anti-money laundering and terrorist financing directive (AML 5) - Key aspects and changes
The fifth anti-money laundering and terrorist financing directive (AML 5) - Key aspects and changes The new directive on the prevention of the use of the financial system for the purposes of money laundering
More informationEBA FINAL draft regulatory technical standards
EBA/RTS/2013/08 13 December 2013 EBA FINAL draft regulatory technical standards on passport notifications under Articles 35, 36 and 39 of Directive 2013/36/EU EBA FINAL draft regulatory technical standards
More informationARTICLE 29 Data Protection Working Party
ARTICLE 29 Data Protection Working Party Brussels, 11th April 2018 Mr Clemens-Martin Auer e-health Network Member State co-chair Director General Federal Ministry of Health, Austria Subject: Agreement
More informationCEBS / CEIOPS-3L / CESR/08-773
CEBS 2008 156/ CEIOPS-3L3-12-08/ CESR/08-773 16 October 2008 Common understanding of the obligations imposed by European Regulation 1781/2006 on the information on the payer accompanying funds transfers
More informationCOMMISSION OF THE EUROPEAN COMMUNITIES. Proposal for a COUNCIL DIRECTIVE
EN EN EN COMMISSION OF THE EUROPEAN COMMUNITIES Brussels, YYY COM(2007) AAA final 2007/BBB (CNS) Proposal for a COUNCIL DIRECTIVE amending Directive 2006/112/EC on the common system of value added tax,
More informationCOMMISSION DELEGATED REGULATION (EU) /... of
EUROPEAN COMMISSION Brussels, 4.12.2017 C(2017) 7967 final COMMISSION DELEGATED REGULATION (EU) /... of 4.12.2017 supplementing Regulation (EU) 2015/760 of the European Parliament and of the Council with
More information17 December Consultation Paper on Implementation Guidelines regarding. Instruments referred to in Article 57(a) of Directive 2006/48/EC recast
17 December 2009 Consultation Paper on Implementation Guidelines regarding Instruments referred to in Article 57(a) of Directive 2006/48/EC recast (CP 33) Introduction 1. The latest amendments to the Capital
More informationEuropean Association of Co-operative Banks Groupement Européen des Banques Coopératives Europäische Vereinigung der Genossenschaftsbanken
Brussels, 21 March 2013 EACB draft position paper on EBA discussion paper on retail deposits subject to higher outflows for the purposes of liquidity reporting under the CRR The voice of 3.800 local and
More informationWIND OF CHANGE: Risk Assessment. Anti-Money Laundering, Countering Terrorism Financing, Application of International Sanctions
WIND OF CHANGE: Risk Assessment Anti-Money Laundering, Countering Terrorism Financing, Application of International Sanctions The 4th EU Anti-Money Laundering Directive encompasses significant changes
More informationDeutsche Börse Group
Deutsche Börse Group Response to the European Commission s Green Paper on Financial Services Policy (2005-2010) COM (2005) 177 1 A. Introduction Deutsche Börse Group welcomes the opportunity to respond
More informationFeedback statement. Responses to the public consultation on a draft Guideline and Recommendation of the European Central Bank
Feedback statement Responses to the public consultation on a draft Guideline and Recommendation of the European Central Bank On the exercise of options and discretions available in Union law for less significant
More information"Discussion circle" on budgetary procedure
THE EUROPEAN CONVTION Brussels, 24 March 2003 THE SECRETARIAT CERCLE II Working document 05 "Discussion circle" on budgetary procedure Subject : Proposal of M. David O'Sullivan, alternate member of the
More informationChina s Market Economy Status: the Commission proposal to change the anti-dumping methodology for Non-Market Economy countries. AEGIS EUROPE position
China s Market Economy Status: the Commission proposal to change the anti-dumping methodology for Non-Market Economy countries AEGIS EUROPE position MARCH 2017 Key messages: Ensure automatic application
More informationBen S Bernanke: Modern risk management and banking supervision
Ben S Bernanke: Modern risk management and banking supervision Remarks by Mr Ben S Bernanke, Chairman of the Board of Governors of the US Federal Reserve System, at the Stonier Graduate School of Banking,
More informationEconomic assessment of public service contracts. in the field of passenger transport. under application of Regulation 1370/2007
30 OCTOBER 2012 Economic assessment of public service contracts in the field of passenger transport under application of Regulation 1370/2007 Views and recommendations from the public transport undertakings
More informationThe application of the Mutual Recognition Regulation to non-ce marked construction products
EN EUROPEAN COMMISSION ENTERPRISE AND INDUSTRY DIRECTORATE-GENERAL Guidance document 1 Brussels, 13.10.2011 - The application of the Mutual Recognition Regulation to non-ce marked construction products
More informationEQUITY MASTER SECURITIES (Pvt.) LIMITED KNOWYOUR CUSTOMER (KYC) AND CUSTOMER DUE DILIGENCE (CDD) POLICES AND PORCEDURES
EQUITY MASTER SECURITIES (Pvt.) LIMITED KNOWYOUR CUSTOMER (KYC) AND CUSTOMER DUE DILIGENCE (CDD) POLICES AND PORCEDURES Know Your Customer(KYC) and Customer Due Diligence (CDD) policies and procedures
More informationECB-PUBLIC OPINION OF THE EUROPEAN CENTRAL BANK. of 27 November 2012
EN ECB-PUBLIC OPINION OF THE EUROPEAN CENTRAL BANK of 27 November 2012 on various draft regulatory and implementing technical standards submitted by the European Securities and Markets Authority to the
More informationI. The PNR agreements
Comments of the EDPS on different international agreements, notably the EU-US and EU-AUS PNR agreements, the EU-US TFTP agreement, and the need of a comprehensive approach to international data exchange
More informationEngaging title in Green Descriptive element in Blue 2 lines if needed
The fourth EU anti-money laundering directive Summarising the changes Deloitte Malta Financial Advisory Engaging title in Green Descriptive element in Blue 2 lines if needed Second line optional lorem
More informationThe Information about People with Significant Control (Amendment) Regulations 2017 (PSC 2017) also came into force on 26 June2017.
Overview of Changes Introduced by The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 which came into force on the 26 th of June 2017 (MLR 2017).
More informationThe Handbook on Countering Financial Crime & Terrorist Financing
The Handbook on Countering Financial Crime & Terrorist Financing Financial Crime Division Fiona Crocker Paul Robinson 28 November 2018 Format Schedule 3 Requirements - Blue Boxes Commission Rules - Red
More informationPROPOSAL FOR AMENDMENTS
CEEP.2015 Orig. EN March 2015 PROPOSAL FOR AMENDMENTS Regulation on the European Fund for Strategic Investments (COM(2015) 10 final) EUROPEAN CENTER FOR EMPLOYERS AND ENTREPRISES PROVIDING PUBLIC SERVICES
More informationCOMPROMISE AMENDMENTS 1-8
EUROPEAN PARLIAMT 2014-2019 Committee on the Environment, Public Health and Food Safety 23.2.2015 2014/0011(COD) COMPROMISE AMDMTS 1-8 Draft report Ivo Belet (PE541.353v02-00) on the proposal for a decision
More informationJonathan Faull Director General, Financial Stability, Financial Services and Capital Markets Union European Commission 1049 Brussels [XX Month] 2015
Jonathan Faull Director General, Financial Stability, Financial Services and Capital Markets Union European Commission 1049 Brussels [XX Month] 2015 Dear Mr Faull Adoption of (Amendments to IFRS 10, IFRS
More informationConsultation on Supervisory reporting requirements for leverage ratio (EBA/CP/2012/06)
Consultation on Supervisory reporting requirements for leverage ratio (EBA/CP/2012/06) BNPP general comments We welcome the opportunity to comment the consultation paper on draft ITS on supervisory reporting
More informationCOMMISSION DELEGATED REGULATION (EU) /... of
EUROPEAN COMMISSION Brussels, 24.11.2016 C(2016) 7495 final COMMISSION DELEGATED REGULATION (EU) /... of 24.11.2016 amending Commission Delegated Regulation (EU) 2016/1675 supplementing Directive (EU)
More informationHaving regard to the Treaty on the Functioning of the European Union, and in particular Article 114 thereof,
L 345/96 Official Journal of the European Union 27.12.2017 DIRECTIVE (EU) 2017/2399 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 12 December 2017 amending Directive 2014/59/EU as regards the ranking
More informationReview of the Money Laundering Regulations 2007: The Government Response
Response to the HM Treasury consultation paper Review of the Money Laundering Regulations 2007: The Government Response September 2011 Fraud Advisory Panel Registered office: Chartered Accountants Hall,
More informationJERSEY FINANCIAL SERVICES COMMISSION 5 TH ANNIVERSARY SEMINAR FATF REVISED 40 RECOMMENDATIONS
JERSEY FINANCIAL SERVICES COMMISSION 5 TH ANNIVERSARY SEMINAR 1. Introduction 1.0 The FATF Forty Recommendations have been revised and these revised Recommendations are with immediate effect the new international
More informationCOMMON UNDERSTANDING BETWEEN EU MEMBER STATES
COMMON UNDERSTANDING BETWEEN EU MEMBER STATES ON THE PROCEDURE AND CRITERIA FOR THE RECOGNITION OF THIRD COUNTRIES 1 EQUIVALENCE UNDER DIRECTIVE 2005/60/EC ON THE PREVENTION OF THE USE OF THE FINANCIAL
More informationNEW ZEALAND S NEW AML/CFT REGIME A brief overview and some challenges will it stand the test of time?
NEW ZEALAND S NEW AML/CFT REGIME A brief overview and some challenges will it stand the test of time? Paper prepared for the Banking & Financial Services Law Association 2013 Annual Conference Bradley
More informationNon-Paper from the services of DG Competition for discussion at a first Multilateral Meeting with experts from the Member States
REVIEW OF THE REGIONAL AID GUIDELINES Non-Paper from the services of DG Competition for discussion at a first Multilateral Meeting with experts from the Member States 1. INTRODUCTION Following informal
More informationABI s remarks on European Commission s consultation on Short Selling
ABI s remarks on European Commission s consultation on Short Selling 09/07/2010 POSITION PAPER Italian Banking Association, Piazza del Gesù 49, 00186, Rome, Italy Interest Representative ID number: 51725251793-16
More informationConsultation Paper: Improving New Zealand s ability to tackle money laundering and terrorist financing
Submission to the Ministry of Justice on the Consultation Paper: Improving New Zealand s ability to tackle money laundering and terrorist financing 16 September 2016 NEW ZEALAND BANKERS ASSOCIATION Level
More informationCOMMISSION DELEGATED REGULATION (EU) No /.. of
EUROPEAN COMMISSION Brussels, 8.10.2014 C(2014) 7164 final COMMISSION DELEGATED REGULATION (EU) No /.. of 8.10.2014 on the provisional system of instalments on contributions to cover the administrative
More informationThe new anti-money laundering directives Summarizing the changes and providing an update
The new anti-money laundering directives Summarizing the changes and providing an update 00 01 Introduction Recent global and European developments call for the need to strengthen the EU s efforts to combat
More informationSWITZERLAND. AM056e-X 1 EB
SWITZERLAND AM056e-X 1 EB WRITTEN STATEMENT BY MS BEATRICE MASER-MALLOR AMBASSADOR ALTERNATE GOVERNOR FOR SWITZERLAND ON BEHALF OF SWITZERLAND I would like to thank the Polish government for hosting the
More informationEUROPEAN COMMISSION S PUBLIC CONSULTATION ON DERIVATIVES AND MARKET INFRASTRUCTURES
EUROPEAN COMMISSION S PUBLIC CONSULTATION ON DERIVATIVES AND MARKET INFRASTRUCTURES EUROSYSTEM CONTRIBUTION 1 INTRODUCTION With a view to meeting the G20 s commitment to promote resilience and transparency
More informationECB-PUBLIC OPINION OF THE EUROPEAN CENTRAL BANK. of 22 May on limitations to cash payments (CON/2017/18)
EN ECB-PUBLIC OPINION OF THE EUROPEAN CENTRAL BANK of 22 May 2017 on limitations to cash payments (CON/2017/18) Introduction and legal basis On 23 March 2017, the European Central Bank (ECB) received a
More informationJC/GL/2017/ September Final Guidelines
JC/GL/2017/16 22 September 2017 Final Guidelines Joint Guidelines under Article 25 of Regulation (EU) 2015/847 on the measures payment service providers should take to detect missing or incomplete information
More informationOpinion Draft Regulatory Technical Standard on criteria for establishing when an activity is to be considered ancillary to the main business
Opinion Draft Regulatory Technical Standard on criteria for establishing when an activity is to be considered ancillary to the main business 30 May 2016 ESMA/2016/730 Table of Contents 1 Legal Basis...
More informationDIRECTIVES. COUNCIL DIRECTIVE 2014/48/EU of 24 March 2014 amending Directive 2003/48/EC on taxation of savings income in the form of interest payments
L 111/50 DIRECTIVES COUNCIL DIRECTIVE 2014/48/EU of 24 March 2014 amending Directive 2003/48/EC on taxation of savings income in the form of interest payments THE COUNCIL OF THE EUROPEAN UNION, Having
More informationFinal Report Draft regulatory technical standards on indirect clearing arrangements under EMIR and MiFIR
Final Report Draft regulatory technical standards on indirect clearing arrangements under EMIR and MiFIR 26 May 2016 ESMA/2016/725 Table of Contents 1 Executive Summary... 3 2 Indirect clearing arrangements...
More informationon the Proposal for a Council Regulation on Administrative Cooperation in the field of Excise Duties
Opinion of the European Data Protection Supervisor on the Proposal for a Council Regulation on Administrative Cooperation in the field of Excise Duties THE EUROPEAN DATA PROTECTION SUPERVISOR, Having regard
More information10472/18 JC/NC/jk ECOMP.2.B. Council of the European Union Brussels, 14 September 2018 (OR. en) 10472/18. Interinstitutional File: 2017/0248 (CNS)
Council of the European Union Brussels, 14 September 2018 (OR. en) Interinstitutional File: 2017/0248 (CNS) 10472/18 FISC 276 ECOFIN 667 LEGISLATIVE ACTS AND OTHER INSTRUMTS Subject: COUNCIL REGULATION
More informationMr. Germano Mirabile DG Taxation and Customs Union European Commission Brussels. By
Date Le Président Fédération Av. d Auderghem 22-28/8 des Experts 1040 Bruxelles 13 March 2008 Comptables Tél. 32 (0) 2 285 40 85 Européens Fax: 32 (0) 2 231 11 12 AISBL E-mail: secretariat@fee.be Mr. Germano
More informationSubmitted to the European Commission on 27 July 2017
Opinion Statement PAC 3/2017 on the European Commission Proposal for a Council Directive amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation COM/2016/025
More informationFinal Report. Implementing Technical Standards
EBA/ITS/2016/05 22 September 2016 Final Report Implementing Technical Standards on common procedures, forms and templates for the consultation process between the relevant competent authorities for proposed
More informationCOMMISSION OF THE EUROPEAN COMMUNITIES
EN EN EN COMMISSION OF THE EUROPEAN COMMUNITIES Brussels, 26.2.2009 COM(2009) 83 final 2009/0035 (COD) Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Council Directive
More informationMUHAMMAD AMER RIAZ SECURITIES (PVT) LIMITED KNOWYOUR CUSTOMER (KYC) ANDCUSTOMER DUE DILIGENCE (CDD) POLICES AND PORCEDURES
MUHAMMAD AMER RIAZ SECURITIES (PVT) LIMITED KNOWYOUR CUSTOMER (KYC) ANDCUSTOMER DUE DILIGENCE (CDD) POLICES AND PORCEDURES Document ID KYC/CDD Title Know Your Customer (KYC) and Customer Due Diligence
More informationFinal Report. Guidelines on specification of types of exposures to be associated with high risk under Article 128(3) of Regulation (EU) No 575/2013
FINAL REPORT ON SPECIFICATION OF TYPES OF EXPOSURES TO BE ASSOCIATED WITH HIGH RISK EBA/GL/2019/01 17 January 2019 Final Report Guidelines on specification of types of exposures to be associated with high
More informationEFAMA s position paper on securitisation
EFAMA s position paper on securitisation Executive summary EFAMA 1 is strongly supportive of the efforts deployed by the Commission towards restoring economic growth in Europe. We consider that the development
More informationSecurities and Markets Stakeholder Group Date: 26 May 2014 ESMA/2014/SMSG/030
Securities and Markets Stakeholder Group Date: 26 May 2014 ESMA/2014/SMSG/030 Advice to ESMA Response to ESMA s Consultation Paper on Draft Regulatory Technical Standards on major shareholdings and indicative
More informationESBG (European Savings and Retail Banking Group) Rue Marie-Thérèse, 11 - B-1000 Brussels. ESBG Transparency Register ID
ESBG position paper on the proposal for a Directive of the European Parliament and of the Council amending Directive 2007/36/EC as regards the promotion of long-term involvement of shareholders and Directive
More informationImplementation Guidelines on instruments referred to in Article 57(a) of the CRD -CP 33
Implementation Guidelines on instruments referred to in Article 57(a) of the CRD -CP 33 Public hearing David Guillaume 23 February 2010 Overview Background Objectives of the draft guidelines Definition
More informationA. Context, Subsidiarity Check and Objectives
TITLE OF THE INITIATIVE LEAD DG RESPONSIBLE UNIT AP NUMBER LIKELY TYPE OF INITIATIVE INDICATIVE PLANNING ADDITIONAL INFORMATION INCEPTION IMPACT ASSESSMENT Possible change in the methodology to establish
More informationCOMMISSION DELEGATED REGULATION (EU) /... of
EUROPEAN COMMISSION Brussels, 31.1.2019 C(2019) 646 final COMMISSION DELEGATED REGULATION (EU) /... of 31.1.2019 supplementing Directive (EU) 2015/849 of the European Parliament and of the Council with
More informationCOMMISSION REGULATION (EU)
9.11.2012 Official Journal of the European Union L 310/19 COMMISSION REGULATION (EU) No 1042/2012 of 7 November 2012 amending Regulation (EU) No 1031/2010 to list an auction platform to be appointed by
More informationMs Sabine Lautenschläger Member of the Executive Board European Central Bank By
Association of German Banks P.O. Box 040307 10062 Berlin Germany Ms Sabine Lautenschläger Member of the Executive Board European Central Bank By email: statistics@ecb.europa.eu cc Mr Aurel Schubert - Director
More informationTargeted review of the General Block Exemption Regulation (GBER): Extension to ports (2nd consultation) 1
Targeted review of the General Block Exemption Regulation (GBER): Extension to ports (2nd consultation) 1 Contribution of the European Sea Ports Organisation (ESPO) to the second public consultation round
More information(Legislative acts) DIRECTIVES
15.11.2014 L 330/1 I (Legislative acts) DIRECTIVES DIRECTIVE 2014/95/EU OF THE EUROPEAN PARLIAMT AND OF THE COUNCIL of 22 October 2014 amending Directive 2013/34/EU as regards disclosure of non-financial
More informationAFG s response to the European Commission s questionnaire on cross border distribution of investment funds
CT Réglementation européenne et internationale 28.06.2017 AFG s response to the European Commission s questionnaire on cross border distribution of investment funds Industry questionnaire As a preliminary
More information