Response to consultation on RTS on CCP to strengthen fight against financial crime

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Question 1: Do you agree with the criteria for a requirement to appoint a Central Contact Point (CCP)? In particular, • do you agree that it is proportionate to require the appointment of a CCP where - the number of establishments is equal to, or exceeds, ten; or - the amount of electronic money distributed and redeemed, or the value of the payment transactions executed by such establishments is expected to exceed EUR 3 million per financial year or has exceeded EUR 3 million in the previous financial year? If you do not agree, clearly set out your rationale and provide supporting evidence where available. Please also set out at what level these thresholds should be set instead, and why. • do you agree that Member States should be able to - require all institutions, or certain categories of institutions, to appoint a CCP where this is commensurate with the ML/TF risk associated with the operation of these institutions’ establishments on the Member State’s territory; and - empower competent authorities to require an institution to appoint a CCP where they have reasonable grounds to believe that the establishments of that institution present a high money laundering and terrorist financing risk, even if the criteria in Article 3 (1) and (2) of these draft RTS are not met. If you do not agree, clearly set out your rationale and provide supporting evidence where available.

Yes, it is appropriate and we agree.

Question 2: Do you agree that the functions a CCP must always have are necessary to ensure that • the CCP can ensure, on the appointing institutions’ behalf, establishments’ compliance with the host Member State’s AML/CFT requirements? • Facilitate supervision by the host Member State’s competent authorities? If you do not agree, please explain which functions you think the CCP should have, and why.

Yes, we agree.

Question 3: Do you agree that CCPs should be required to fulfil one or more of the additional functions in Article 6 of these draft RTS where this is commensurate to the ML/TF risk associated with the operation of establishments other than a branch on the host Member State’s territory? If you do not agree, clearly set out your rationale and provide supporting evidence where available. Please also set out whether you think that these additional functions should be core functions instead, and if so, why.

Yes, we agree.

Name of organisation

Austrian Federal Economic Chamber, Division Bank and Insurance