Response to eBA launches consultation to revise its Guidelines on internal governance

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Question 2: Point (d) has been added, throughout the Guidelines references to money laundering and terrorism financing and the institutions obligations have been added, are those references sufficiently clear?

With regards to the the references to money laundering and terrorism financing, could you provide more background on paragraph 43. regarding the suggestion to establish a committee for e.g. AML/CTF. Is there a recommendation as to the size at which it would make sense to establish such a committee, also against the background of the principle of proportionality and taking into account the various business models of financial institutions?

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UBS Europe SE