Response to consultation on Guidelines on risk factors and simplified and enhanced customer due diligence
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We welcome the preparation of pan European Guidelines in this area and believe that the joint ESA’s should, as much as possible, seek to ensure that the Guidelines are implemented and interpreted in a consistent way across jurisdictions.
Lack of jurisdictional consistency on AML/CTF matters can cause complexity and confusion to international investors and may lead to a situation where they favour one jurisdiction over another due to a perceived lighter burden for provision of information and documentation.
a) Do you consider that these guidelines are conducive to firms adopting risk-based, proportionate and effective AML/CFT policies and procedures in line with the requirements set out in Directive (EU) 2015/849?
Yes – we believe by adding detail and giving examples to the requirements set out in Directive (EU) 2015/849 that the guidelines are conducive to firms adopting risk-based, proportionate and effective AML/CFT policies and procedures.b) Do you consider that these guidelines are conducive to competent authorities effectively monitoring firms’ compliance with applicable AML/CFT requirements in relation to individual risk assessments and the application of both simplified and enhanced customer due diligence measures?
We believe that the guidelines are conducive to competent authorities monitoring of firms’ compliance.We welcome the preparation of pan European Guidelines in this area and believe that the joint ESA’s should, as much as possible, seek to ensure that the Guidelines are implemented and interpreted in a consistent way across jurisdictions.
Lack of jurisdictional consistency on AML/CTF matters can cause complexity and confusion to international investors and may lead to a situation where they favour one jurisdiction over another due to a perceived lighter burden for provision of information and documentation.