EMEA REGULATORY DEVELOPMENTS NEWSLETTER

Transcription

1 VOLUME EMEA REGULATORY DEVELOPMENTS NEWSLETTER Dedicated to helping you stay ahead of regulatory change, this newsletter summarises the latest regulatory developments affecting Europe and provides updates on how Northern Trust is evolving to support your requirements. The regulatory calendar provides an overview of the main regulatory milestones scheduled to occur during the next few years. Readers of the electronic version of the newsletter can use the links to the latest regulatory developments. REGULATORY CALENDAR /2015 and beyond 2 EUROPE 3 1. Update on EU regulatory developments 3 2. European Markets Infrastructure Regulation (EMIR) 4 3. Alternative Investment Fund Managers Directive (AIFMD) 6 4. Undertakings for Collective Investment in Transferable Securities (UCITS V) 7 UNITED KINGDOM 8 5. Common Investment Fund (CIF) tax benefits 8 6. Client Asset Rules 9 GLOBAL Foreign Account Tax Compliance Act (FATCA) OECD Common Reporting Standard Organisation for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) Action Plan 12 northerntrust.com EMEA Regulatory Developments Newsletter 1 of 13

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3 EUROPE 1. Update on EU regulatory developments OVERVIEW Tax regulation continues to feature prominently, with the Foreign Account Tax Compliance Act (FATCA) having paved the way for the global exchange of information. The Organisation for Economic Co-operation and Development (OECD) is pressing ahead with the Common Reporting Standard (CRS) as well as a new tax initiative to address Base Erosion and Profit Shifting (BEPS). Although the dust is beginning to settle on the Alternative Investment Fund Managers Directive (AIFMD), there remain ongoing areas of impact, in particular regarding reporting. The final text of the revised regulatory initiative on Undertakings for Collective Investment in Transferable Securities (UCITS V) has been agreed, although further clarity is needed on various matters including the requirement that both the UCITS management company and its depositary act independently and solely in the interest of the fund and its investors. The European Central Bank (ECB) assumed its new banking supervision responsibilities on 4 November 2014, signifying an important milestone towards a banking union in Europe, with the aim of building an integrated financial framework to safeguard financial stability and minimise the costs of bank failures. TIMELINE OF UPDATES September UCITS V and CSDR entered into force. 3 October The European Commission (EC) published FAQs on the Central Securities Depositories Regulation. 6 October Most European Economic Area markets successfully migrated their trade settlement cycles to T October Members of European Parliament voted by a large majority in support of the new EC. 26 October Publication of the result of the Asset Quality Review of the ECB for the banks falling under direct supervision of the ECB from 4 November 2014 onwards. 28/29 October Boosting international cooperation in tax matters was high on the agenda at the meeting of the Global Forum on Transparency and Exchange of Information for Tax Purposes. 1 November The EC began its five year term under new president Jean-Claude Juncker, bringing the period of reduced European rulemaking to an end. We will no doubt start to see interesting regulatory developments from Brussels including agreement on the scope of the EU Financial Transaction Tax, further clarity in relation to the directive on Packaged Retail and Insurance-based Investment Products (PRIIPs) and progression on the regulation of shadow banking. To Learn More eur-lex.europa.eu/legal-content/en/txt/pdf/?uri=celex:32014l0091&from=en eur-lex.europa.eu/legal-content/en/txt/pdf/?uri=celex:32014r0909&from=en ec.europa.eu/news/eu_explained/141022_en.htm northerntrust.com EMEA Regulatory Developments Newsletter 3 of 13

4 2. The European Markets Infrastructure Regulation (EMIR) All OTC derivative users, although please note three year exemption from the central clearing obligation. Key takeaway Under EMIR, arrangements must be set up with clearing houses, reporting and reconciliation requirements must be met and collateral requirements will impact treasury demands and liquidity needs. Overview Originating from principles agreed by the G20, EMIR aims to reduce risk and increase transparency in the over-the-counter (OTC) derivatives market. Key Provisions EMIR is broad in scope, imposing requirements on all types and sizes of entities that enter into any form of derivative contract. The main provisions of EMIR are: Standardised OTC derivatives must be cleared through central clearing houses All derivatives trades must be reported to centralised trade repositories Non-cleared contracts will be subject to higher capital requirements and risk mitigation techniques Regulatory Technical Standards (RTS) In September, the European Securities and Markets Authority (ESMA) issued the final draft RTS for the central clearing of Interest Rate Swaps (IRS). The RTS define those types of IRS contracts which will have to be centrally cleared, the types of counterparties covered by the obligation and the dates by which central clearing of IRS will become mandatory for them. Four IRS classes will need to be centrally cleared under EMIR: Product Type CurrenCy Maturity Fixed-to-float IRS EUR, GBP, USD JPY 28D 50Y 28D 30Y Basis Swaps EUR, GBP, USD JPY 28D 50Y 28D 30Y FRA EUR, GBP, USD 3D 3Y OIS EUR, GBP, USD 7D 3Y Phasing in of the central clearing obligation will begin in June This will affect the following groups: 1. Clearing members (six months after the RTS entered into force). 2. Financial counterparties and other AIFs classified as non-financial counterparties (12 months after the RTS entered into force) with an aggregate month-end average notional amount of non-centrally cleared derivatives above EUR8 billion. 3. Financial counterparties and other AIFs classified as non-financial counterparty with a low level of activity in uncleared derivatives (18 months after the RTS entered into force). 4. Non-financial counterparties (three years after the RTS entered into force). The RTS have been submitted to the EC for endorsement in the form of Commission regulations. The EC has three months to decide whether to endorse the RTS, which it may do in part only or with amendments. Assuming the EC endorses the RTS, the Parliament and Council have one month to object to the RTS. If they do not object, the RTS will be published in the Official Journal of the EU and enter into force 20 days thereafter. That date will be the start of the phase-in approach outlined above. northerntrust.com EMEA Regulatory Developments Newsletter 4 of 13

5 Consultation In addition to the submission of the draft RTS to the EC for interest rate derivatives, ESMA has also published a consultation paper around a potential clearing obligation for non-deliverable FX forwards. ESMA has proposed to include cash-settled non-deliverable FX forwards in 11 currencies against the USD in a clearing obligation. The consultation closes on 6 November. In view of the clearing obligation gradually being phased in Europe, ESMA has further conducted a consultation regarding the treatment of exposure limits of UCITS funds for OTC derivatives. The consultation closed on 22 October. Next Steps (expected later in 2014) Final RTS on the clearing obligation for credit derivatives. A report by the EC which should provide clarity on an extension for the pension fund clearing exemption. The final RTS for bilateral collateralisation. While these are spearheaded by EBA, all three European Supervisory Authorities (i.e. EBA, ESA and EIOPA) need to provide their input and have been involved in the consultation process. As clients look to move into the centrally cleared environment, many asset owners have raised concern about the safety of their assets as they move through the clearing cycle. Northern Trust continues to evolve our derivatives clearing services. Combined with Northern Trust s custody and collateral management, these services help clients respond to the new regulatory requirements and reduce the burden of the transition to a cleared derivative environment under EMIR. The Northern Trust solution will provide clients with a set of account structures for cleared derivatives designed to enhance asset transparency, reduce exposure and increase asset safety. To Learn More UCITS-OTC-financial-derivative-transacti northerntrust.com EMEA Regulatory Developments Newsletter 5 of 13

6 3. The Alternative Investment Fund Managers Directive (AIFMD) Asset managers holding any fund not already regulated by UCITS that is managed, domiciled and/or distributed in the EU. Insurance Firms: AIFs are required to hold either additional capital or professional indemnity insurance, which may lead to a rise in the demand for this product. Pension funds: Costs associated with investing AIFMD compliant investment funds will almost certainly be higher, but will enhance investor protection and reduce risk. Key takeaway Asset managers and AIFs must act as though authorised if their passport application was submitted prior to 22 July Overview The one-year transition period for the implementation of AIFMD came to an end on 22 July By this date relevant managers had to apply for authorisation as an Alternative Investment Manager (AIFM), and had to be compliant with the Directive. Next Steps For many funds, the Annex IV reporting deadlines are fast approaching. Given the volume of data required to be aggregated and enriched by the Annex IV reporting requirements, there is no room for complacency. Immediate steps should be taken to ensure compliance. Northern Trust continues to work closely with our clients throughout the AIFMD implementation process. To support managers implementing AIFMD, Northern Trust has expanded its depositary services across multiple fund types, asset classes, fund locations and investment strategies, now offering depositary services in the United Kingdom and the Netherlands, in addition to our existing services in Ireland, Luxembourg and Channel Islands. In April 2014, Northern Trust received full regulatory permissions to act as trustee/depositary for UCITS and for AIFs. To help clients meet AIFMD requirements, Northern Trust has implemented a full depositary and an offshore depositary (for non-eu funds) service. In addition, we have launched an AIFMD regulatory reporting service that supports asset managers across multiple domiciles and locations. Our flexible services, supported by a dedicated team of experts and specialist technology, provide a range of services including: Signature ready return in partnership with a leading software vendor, Northern Trust will collect, aggregate and format the required data to deliver a signature ready report to the regulator on our clients behalf Data service an extract from Northern Trust s systems delivered to clients for completion prior to your submission to the regulator Certain regulatory matters await further clarification, including the important issue of segregation at prime brokers. Northern Trust continues to monitor any progress made in relation to such matters and will provide further information when available. northerntrust.com EMEA Regulatory Developments Newsletter 6 of 13

7 4. Undertakings for Collective Investment in Transferable Securities (UCITS V) Direct impact to asset managers and an indirect impact to pension funds and insurance firms. Key takeaway With the final text of the UCITS V Directive agreed, steps should be taken to amend remuneration policies and review depositary arrangements to ensure compliance with these new rules. Overview The UCITS regime facilitates fund distribution across EU member states. The latest directive amends the regulatory framework to address discrepancies between national provisions and to provide additional protection for UCITS investors. A key goal of UCITS V is to align the UCITS regime with the depositary rules, rules on remuneration and sanction provisions under AIFMD. UCITS V entered into force on 17 September 2014, meaning member states must adopt and publish the laws, regulations and administrative provisions necessary to comply with the Directive by 18 March Key Provisions The draft UCITS V Directive covers three key areas: New depositary liability requirements; depositary liability cannot be delegated, and is extended to market infrastructure as use of a CSD is considered a delegation of custody. Furthermore, in order to enhance the protection of investors assets, UCITS V upgrades the duties and liabilities of UCITS depositaries by clarifying the safekeeping, oversight and cash flow monitoring functions. Increased disclosure requirements including greater transparency in manager remuneration. Sanctions for breaches of the UCITS rules. Independence between depositary and management company UCITS V requires that both the UCITS management company and its depositary act independently and solely in the interest of the fund and its investors. In order to fulfil the independence requirement, ESMA has proposed a combination of measures based on management and governance as well as structural links. UCITS KIIDs and PRIIPs KIDs The regulation regarding Packaged Retail and Insurance-based Investment Products (PRIIPs) is the latest EU development which aims to increase consumer protection as more markets open up for retail sector investment. Under the regulation, a standardised disclosure document called a Key Investor Document (KID) must be provided to retail investors before investing in PRIIPs. The PRIIP manufacturer is responsible for producing each KID which should be comprehensible on its own terms (and no longer than three pages of A4). For UCITS, the Key Investor Information Document (KIID) will continue to be the applicable disclosure document. However, given the desire for consistency in disclosure, it is intended that eventually the UCITS KIID will need to be aligned to the PRIIPs KID. Whether this means replacing the UCITS KIID with the PRIIPs KID, or making amendments to harmonise the two disclosure documents, has not yet been decided. There is a transitional period of 5 years before the disclosure requirements for UCITS are intended to be considered in relation to the PRIIPs regime. northerntrust.com EMEA Regulatory Developments Newsletter 7 of 13

8 Next steps Feedback was received on ESMA s proposed insolvency protection and independence of the UCITS depositary function measures on 24 October The technical advice is now being finalised and is expected to be submitted to the EC by the end of November NORTHERN TRUST Actions Northern Trust continues to monitor any progress made in relation to such matters and will provide further information when available. With regards to disclosure, in light of UCITS V and the PRIIPs regulation, we are currently holistically revaluating our KIID service and considering expanding it to potentially include distribution and hosting. United Kingdom 5. UK Common Investment Fund (CIF) tax benefits UK CIFs. Key takeaway Entitlement to tax benefits in the Dutch market can now be claimed via a new and streamlined process. Northern Trust expects to be able to file these claims on our clients behalf. Please contact your Northern Trust representative for further details. Overview A CIF is an arrangement whereby a number of UK pension schemes or charities pool some or all their investments into a common fund. The Dutch Tax and Customs Administration (TCA) has historically not recognised a UK CIF as being eligible to claim tax benefits unless complex documentation was completed at investor level that breaks down percentage ownership and allocation of potential reclaims. Following Northern Trust s extensive lobbying of the UK s HM Treasury and the TCA, UK CIFs are now eligible to claim tax benefits in the Dutch market via a streamlined approach. We have worked with HM Treasury over the past year to achieve this positive outcome. The agreement became effective on 19 September 2014 with a retrospective application. Northern Trust is working with the TCA to determine how far back claims can be filed in relation to this. We will provide further information when available. Northern Trust will review client entitlements on a case-by-case by basis and advise accordingly. northerntrust.com EMEA Regulatory Developments Newsletter 8 of 13

9 6. Policy Statement 14/09 the Client Assets Protection Regime (CASS Rules) Asset managers. Key takeaway By 1 December 2014, a new standardised template must be used for acknowledgement letters. Overview In June 2014, the Financial Conduct Authority (FCA) published a policy statement setting out material changes to the existing rules relating to custody assets and client money. These rule changes aim to achieve a greater return of client assets following the insolvency of an investment firm and improve the speed at which assets are returned. Key Provisions The way in which banks, brokers and asset managers handle client money and assets will change under the amended rules. Customer relationships, outsourcing arrangements, operations, IT systems, policies and procedures will be affected as a result. The extension of the reporting obligations to cover all clients, not just retail clients, will significantly increase the reporting burden under the CASS rules. Next Steps By 1 December 2014 a new standardised template for acknowledgement letters will take effect, along with new rules for the treatment of unclaimed client money balances. Revised requirements for firms operating an alternative approach to client money segregation will also come into play. By 1 June 2015 new rules that require the repapering of client documentation will take effect. There is currently a lack of clarity from the regulator in relation to some aspects of the changes to the CASS rules. In particular, the circumstances under which money received for subscriptions and money for redemptions should be treated as client money remain unclear. The FCA has made it clear that one investor s money cannot be used for another investor s transaction. For example, a cheque deposited into the client money account must be cleared funds before it can be used to make a creation payment. In these instances, a shortfall must be funded. Decisions must be made between parties as it must be established who will fund the shortfall. On 29 August, Northern Trust held a client workshop during which business and compliance subject matter experts came together to discuss the CASS rule changes and the key impacts to the environment. Northern Trust continues to contribute to a number of industry forums regarding CASS rules to ensure we remain at the forefront of the ongoing debates regarding certain aspects of the new rules and clarifications. northerntrust.com EMEA Regulatory Developments Newsletter 9 of 13

10 GlOBAl 7. Update on the Foreign Account Tax Compliance Act (FATCA) All asset managers, AIFs and insurance firms making payments. Key takeaways Requirements include: Register legal entities, funds or vehicles with the IRS as necessary. Request FATCA US withholding tax certificates from investors. Effective since 1 July 2014, FATCA due diligence must be completed for new individual account holders, and, in certain jurisdictions, entity accounts. Northern Trust clients with previous US tax forms on file with us for existing accounts are not required to provide new versions of tax forms at this time. Northern Trust will reach out to impacted clients individually when a new tax form is required. The timing or need for Northern Trust to receive new tax forms from clients will depend on individual circumstances. Northern Trust will provide sufficient notice before existing clients are required to submit new forms. OVERVIEW FATCA, which became US law in 2010 and portions of which became effective on 1 July 2014, imposes significant penalties on foreign financial institutions (FFIs) that fail to agree to conduct due diligence on all investors, report on US and non-compliant investors and potentially withhold payments to non-compliant investors. FFIs (with rare exceptions) are also required to register with the Internal Revenue Service (IRS) to obtain a Global Intermediary Identification Number (GIIN) that the FFI will provide to third parties to confirm its FATCA-compliant status. Any FFI that fails to comply will be subject to a 30% FATCA withholding penalty on all payments of US-source income received by the fund. Recent Updates On 1 July 2014, FATCA due diligence requirements became effective for new individual accounts. The US Internal Revenue Service allowed an extension until 1 January 2015 for new entity accounts. Entity accounts opened between 1 July and 31 December 2014 are to be treated as "existing" accounts, although with no $250,000 threshold. Certain jurisdictions, including the United Kingdom, have not taken advantage of this change. Throughout June, the IRS published instructions on the final version of the instructions for Form W-8BEN-E (to be used by non-us entities to certify their FATCA status and claim treaty benefits). The IRS list of GIINs for financial institutions that have completed the registration process is published via the IRS website. This searchable list includes approximately 77,000 financial institutions around the world that have registered for purposes of FATCA. Northern Trust successfully completed the FATCA registration and has received GIINs for all of its affiliates and branches that are considered FFIs. These GIINs were included on the initial FATCA FFI list, published by the IRS on 2 June Globally, Northern Trust continues to participate in industry organisations and share perspectives with other industry participants to identify and resolve challenges. We continue to upgrade our systems and operation models to support our FATCA obligations and to assist fund managers in meeting their own FATCA obligations. To learn more The searchable list of FATCA registrants is available at: apps.irs.gov/app/fatcaffilist/flu.jsf. northerntrust.com EMEA Regulatory Developments Newsletter 10 of 13

11 8. The OECD s Common Reporting Standard (CRS) All areas of tax and all Northern Trust clients. Key takeaway The OECD s recent recommendations relating to the prevention of treaty abuse include the introduction of: Treaty preambles to clearly state that their aim is not reduced/ non-taxation Objective and subjective anti-abuse rules incorporated into treaties Anti-abuse rules on certain specific transactions. OVERVIEW Tax authorities are becoming more sophisticated and global in their approach; information exchange is certainly here to stay. In February 2014, the G20 endorsed the Common Reporting Standard for automatic exchange of tax information (CRS). The CRS seeks to establish the automatic exchange of tax information, to provide certain specified account information to the home country s tax administration. Ninety jurisdictions have publically committed to implementation, with 48 countries signed up to be early adopters who are required to undertake first reporting in The United Kingdom, Ireland, Guernsey and The Cayman Islands are all amongst these early adopters. Relationship between the CRS, FATCA and CDOT Similar to US FATCA and the UK Intergovernmental Agreements with the Crown Dependencies and Overseas Territories (CDOT), Financial Institutions (FIs) will be expected to undertake due diligence procedures on pre-existing account holders and obtain additional documentation for new account holders. Unlike US FATCA, FIs will be looking to identify an account holder s country of tax residency, not citizenship. Also unlike US FATCA (but in line with UK CDOT), there is no option for withholding under the CRS. Once the United Kingdom has issued enabling legislation and the CRS has been implemented, it is expected that all reporting under UK CDOT will cease as CRS will effectively provide the same information. Funds in UK CDs and OTs will therefore have to handle the operational complexity and burden of implementing UK FATCA and then adapting to implement the CRS. Key Provisions The CRS introduces governance and transparency requirements including the following: Entities will need to conduct a pre-existing review on investor base, mapping tax residencies (high-value individual entity accounts will need to be completed by 31 December 2016 and low-value individual accounts by 31 December 2017). The exchange of information between tax authorities: by the end of September 2017 for new and pre-existing high value accounts and the end of September 2018 for remaining accounts (or September 2017 depending on when the identification of these accounts occurs) Northern Trust has already updated its systems to include fields for recording tax residence. Furthermore, where possible we are establishing clients tax residences as part of the preexisting review required for US FATCA and UK CDOT. This will ensure we are prepared for the future application of the CRS. Northern Trust intends to offer a service similar in nature to that already being offered to clients for US FATCA and UK CDOT. We continue to monitor the progression of the CRS and will fully review our offering once relevant guidance has been issued by all first adopter participating jurisdictions. Northern Trust continues to participate in various industry-led initiatives to make representations both to the OECD and local tax authorities regarding the implementation of the CRS. northerntrust.com EMEA Regulatory Developments Newsletter 11 of 13

12 9. The Organisation for Economic Co-operation and Development s (OECD) Base Erosion and Profit Shifting (BEPS) Action Plan (the Action Plan): All asset managers, AIFs and insurance firms tax resident in jurisdictions that have indicated that they will adopt the CRS. Key takeaways There are differences between UK CDOT and CRS but there is sufficient overlap. UK CDOT will be short-lived and superseded by CRS. Funds in UK CDs and OTs will have to handle the operational complexity and burden of implementing UK FATCA and then adapting to implement the CRS. Minimise the burden of future compliance with CRS by extending your search criteria of existing client bases as part of FATCA due diligence, to make efforts to establish clients tax residency/residencies. where local data protection laws allow. OVERVIEW BEPS are tax plan strategies that take advantage of gaps in tax rules, or shift profits to locations resulting in little or no tax being paid. The Action Plan, endorsed by the G20 Finance Ministers on 19 July 2013, provides a consensus-based plan to address these issues and ensure that the global tax architecture is equitable and fair. Specifically, the Action Plan sets out 15 areas of work to be undertaken with the aim of addressing a range of tax challenges. Recent Updates On 16 September, the OECD released its first draft recommendations, referred to as soft legislation due to its non-binding impact, for the following action points: Action 2 Action 6 Action 8 Action 13 Neutralising the effects of hybrid mismatch arrangements. Prevent treaty abuse. Transfer pricing aspects of intangibles. Re-examine transfer pricing documentation and country by country reporting In relation to Action 6, which presents the highest anticipated impact to Northern Trust clients, the OECD set out the following recommendations: Treaty preambles should expressly state that the intention is to eliminate double taxation and not create opportunities for reduced or non-taxation through tax evasion or avoidance. Tax treaties should include both an objective anti-abuse limitation of benefits rule (an LOB rule ) and a subjective anti-abuse rule denying a benefit if obtaining that benefit is a principal purpose of the arrangement or transaction (a PPT Rule ). Anti-abuse rules to address further specific transactions which circumvent source taxation. Next Steps Public consultations will take place at the OECD headquarters in Paris in early The final recommendations regarding Action 6 will be released in September 2015, with the full Action Plan completion date set for December The Action Plan will potentially change domestic tax law, requiring greater transparency. This in turn could precipitate the need for increased documentation and information sharing. Northern Trust is closely monitoring the progression of the action plan. Through our active membership with the Association of Global Custodians and the British Bankers Association, Northern Trust continues to lobby the OECD with regards to the implications of the proposals and the impact to our client base. To Learn More northerntrust.com EMEA Regulatory Developments Newsletter 12 of 13

13 Feedback Northern Trust is committed to providing our clients with sufficient information through many mediums to allow for full and effective consideration of regulatory change. Your feedback is invaluable to us; our aim is to ensure this newsletter provides updates which are aligned to your needs. If there are any topics which are of particular importance to you please advise your Northern Trust contact and we will seek to address them in upcoming editions of the newsletter. IRS CIRCULAR 230 NOTICE: To the extent that this material concerns tax matters, it is not intended to be used and cannot be used by a taxpayer for the purpose of avoiding penalties that may be imposed by law. For more information about this notice, see northerntrust.com/ circular Northern Trust Corporation. Head Office: 50 South La Salle Street, Chicago, Illinois U.S.A. Incorporated with limited liability in the U.S. Products and services provided by subsidiaries of Northern Trust Corporation may vary in different markets and are offered in accordance with local regulation. This material is directed to professional clients only and is not intended for retail clients. For Asia-Pacific markets, it is directed to institutional investors, expert investors and professional investors only and should not be relied upon by retail investors. For legal and regulatory information about our offices and legal entities, visit northerntrust. com/disclosures. The following information is provided to comply with local disclosure requirements: The Northern Trust Company, London Branch; Northern Trust Global Services Limited; Northern Trust Global Investments Limited. The following information is provided to comply with Article 9(a) of The Central Bank of the UAE s Board of Directors Resolution No 57/3/1996 Regarding the Regulation for Representative Offices: Northern Trust Global Services Limited, Abu Dhabi Representative Office. Northern Trust Global Service Limited Luxembourg Branch, 2, rue Albert Borschette, L-1246, Luxembourg, Succursale d une société de droit étranger RCS B Northern Trust Luxembourg Management Company S.A., 2, rue Albert Borschette, L-1246, Luxembourg, Société anonyme RCS B Northern Trust (Guernsey) Limited (2651)/Northern Trust Fiduciary Services (Guernsey) Limited (29806)/Northern Trust International Fund Administration Services (Guernsey) Limited (15532) Registered Office: Trafalgar Court Les Banques, St Peter Port, Guernsey GY1 3DA. northerntrust.com EMEA Regulatory Developments Newsletter 13 of 13 Q52179 (11/14)