Response to consultation on revised Guidelines on money laundering and terrorist financing (ML/TF) risk factors

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Question 1: Do you have any comments on the proposed changes to definitions.

Regarding Guideline 21.5, a), i) point, the HFIU proposes to define precisely which sources are considered reliable and independent.

Regarding Guideline 21.5, a) i) point, the HFIU proposes to clearly specify the range of those events, phenomena that are considered extremism.

Guideline, 21.5. b) ii c) point mentions the term ’source of crypto assets’ for the first time.
The HFIU proposes to define precisely the term ’source of crypto assets’ and which documents or certificates can be accepted as an evidence by CASPs .
We highlight the importance of this definition since the MiCA regulation does not contain it.

Question 2: Do you have any comments on the proposed changes to Guideline 1.

The HFIU agrees with the content of the Guideline 1 and no further comments are made.

Question 3: Do you have any comments on the proposed changes to Guideline 2.

The HFIU agrees with the content of the Guideline 2 and no further comments are made.

Question 4: Do you have any comments on the proposed changes to Guideline 4.

The HFIU agrees with the content of the Guideline 4 and no further comments are made.

Question 5: Do you have any comments on the proposed changes to Guideline 6.

The HFIU agrees with the content of the Guideline 6 and no further comments are made.

Question 6: Do you have any comments on the proposed changes to Guideline 8.

The HFIU agrees with the content of the Guideline 8 and no further comments are made.

Question 7: Do you have any comments on the proposed changes to Guideline 9.

The HFIU agrees with the content of the Guideline 9 and no further comments are made.

Question 8: Do you have any comments on the proposed changes to Guideline 10, 15 and 17.

The HFIU agrees with the contents of Guidelines 10, 15 and 17 and no further comments are made.

Question 9: Do you have any comments on the proposed changes to Guideline 21.

The HFIU agrees with the content of the Guideline 21 and no further comments are made.

Name of the organization

Hungarian Financial Intelligence Unit (HFIU)