Response to consultation on draft Guidelines under Articles 17 and 18(4) of Directive (EU) 2015/849 on customer due diligence and ML/TF risk factors

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Question 1: Do you have any comments with the proposed changes to the Definitions section of the Guidelines?

N/A

Question 2: Do you have any comments on the proposed amendments to Guideline 1 on risk assessment?

N/A

Question 3: Do you have any comments on the proposed amendments to Guideline 2 on identifying ML/TF risk factors?

N/A

Question 4: Do you have any comments on the proposed amendments and additions in Guideline 4 on CCD measures to be applied by all firms?

N/A

Question 5: Do you have any comments on the amendments to Guideline 5 on record keeping?

N/A

Question 6: Do you have any comments on Guideline 6 on training?

N/A

Question 7: Do you have any comments on the amendments to Guideline 7 on reviewing effectiveness?

N/A

Question 8: Do you have any comments on the proposed amendments to Guideline 8 for correspondent banks?

N/A

Question 9: Do you have any comments on the proposed amendments to Guideline 9 for retail banks?

N/A

Question 10: Do you have any comments on the proposed amendments to Guideline 10 for electronic money issuers?

N/A

Question 11: Do you have any comments on the proposed amendments to Guideline 11 for money remitters?

N/A

Question 12: Do you have any comments on the proposed amendments to Guideline 12 for wealth management?

N/A

Question 13: Do you have any comments on the proposed amendments to Guideline 13 for trade finance providers?

N/A

Question 14: Do you have any comments on the proposed amendments to Guideline 14 for life insurance undertakings?

N/A

Question 15: Do you have any comments on the proposed amendments to Guideline 15 for investment firms?

N/A

Question 16: Do you have any comments on the proposed amendments to Guideline 16 for providers of investment funds and the definition of customer in this Guideline?

N/A

Question 17: Do you have any comments on the additional sector-specific Guideline 17 on crowdfunding platforms?

N/A

Question 18: Do you have any comments on the additional sector-specific Guideline 18 on account information and payment initiation service providers?

Yes, please see attached PDF response

Question 19: Do you have any comments on the additional sector-specific Guideline 19 on currency exchanges?

N/A

Question 20: Do you have any comments on the additional sector-specific Guideline 20 on corporate finance?

N/A

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Name of the organization

Financial Data and Technology Association (FDATA) Europe