Response to consultation on draft amending Guidelines on risk-based AML/CFT supervision

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Q3. Do you have any comments on the proposed changes to the Guideline 4.2 ‘Step 1- Identification of risk and mitigating factors’?

We agree in general on the proposed amendments to the Guidelines concerning the features of a risk-based approach for AML/CFT supervisory. In particular, we agree on the engagement of industry bodies as potential sources of additional information which could be consulted by Competent Authorities in order to identify and understand risk factors. We consider necessary to bring to a higher level the collaboration between professional associations of the involved categories and Authorities, especially where these latter have to rely on distribution channels to manage ML/FT risks. It is fundamental that Competent Authorities understand in detail the organizational methods of each category and the risks associated with common features, like the type of products and services offered, the distribution channels used and the kind of served customers.

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