Response to consultation on Guidelines on internal policies, procedures and controls to ensure the implementation of Union and national restrictive measures
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Question 1: Do you agree with the proposed provisions? If you do not agree, please explain how you think these provisions should be amended, and set out why they should be amended. Please provide evidence of the impact these provisions would have if they were maintained as drafted'?
We see merit in many of the proposals. We do however have some suggestions and requests for clarification. We provide both general comments applying to the texts overall, and specific comments relating to individual elements of the texts, in the submission document attached.
It would be our pleasure to explain our comments and suggestions in greater detail in a meeting, either in person or via video. We will be in touch with your services to suggest a date.
Thank you for the ability to comment on these proposals. We look forward to assisting with producing the most well-informed Guidelines possible in the period to December.
With very best wishes,
The Association of Financial Markets in Europe.