Response to consultation on Guidelines on risk factors and simplified and enhanced customer due diligence

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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, supports the draft Joint Guidelines as they provide valuable and clear guidance to credit institutions on the factors, measures and information to be considered when performing their obligation to assess money laundering and terrorism financing risks.

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?

.

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Name of organisation

ACCIS (Association of Consumer Credit Information Suppliers)