Response to consultation on draft Guidelines on the role, tasks and responsibilities AML/CFT compliance officers

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1. Do you have any comments on the section ‘Subject matter, scope and definitions’?

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2. Do you have any comments on Guideline 4.1 ‘Role and responsibilities of the management body in the AML/CFT framework and of the senior manager responsible for AML/CFT’?

PREVENTION OF MONEY-LAUNDERING IN CASE OF DIGITAL INSUFFICIENCY OR TOTAL DIGITAL FALLOUT, BY MEANS OF REALIZATION OF PAPER REPRODUCTIONS OF INCOME AND EXPENSES ON AML/CFT MANAGEMENT LEVEL, IF APPLICCABLE ALSO CONCERNING CLIENTS' BANKACCOUNTS' IMAGES.

3. Do you have any comments on Guideline 4.2 ‘Role and responsibilities of the AML/CFT compliance officer’?

PREVENTION OF MONEY-LAUNDERING IN CASE OF DIGITAL INSUFFICIENCY OR TOTAL DIGITAL FALLOUT, BY MEANS OF REALIZATION OF PAPER REPRODUCTIONS OF INCOME AND EXPENSES ON AML/CFT COMPLIANCE OFFICERS LEVEL, IF APPLICCABLE ALSO CONCERNING CLIENTS' BANKACCOUNTS' IMAGES.

4. Do you have any comments on Guideline 4.3 ‘Organisation of the AML/CFT compliance function at group level’?

PREVENTION OF MONEY-LAUNDERING IN CASE OF DIGITAL INSUFFICIENCY OR TOTAL DIGITAL FALLOUT, BY MEANS OF REALIZATION OF PAPER REPRODUCTIONS OF INCOME AND EXPENSES ON AML/CFT COMPLIANCE FUNCTION AT GROUP LEVEL, IF APPLICCABLE ALSO CONCERNING CLIENTS' BANKACCOUNTS' IMAGES.

5. Do you have any comments on Guideline 4.4 ‘Review of the AML/CFT compliance function by competent authorities’?

PREVENTION OF MONEY-LAUNDERING IN CASE OF DIGITAL INSUFFICIENCY OR TOTAL DIGITAL FALLOUT , BY MEANS OF REALIZATION OF PAPER REPRODUCTIONS OF INCOME AND
EXPENSES ON AML/CFT COMPLIANCE FUNCTIONS AT LEVEL OF COMPETENT AUTHORITIES, IF APPLICCABLE ALSO CONCERNING CLIENTS' BANKACCOUNTS' IMAGES.

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