Response to consultation on proposed RTS in the context of the EBA’s response to the European Commission’s Call for advice on new AMLA mandates
3a: What will be the impact, in terms of cost, for credit and financial institutions to provide this new set of data in the short, medium and long term?
The proposed list would significantly increase the number of data points from 25 datapoints to 85 here in Denmark. This would be excessive and unhelpful, leading to unnecessary bureaucracy without tangible benefits. As we understand the 25 datapoints that danish companies report today to the Danish FSA is enough for the Danish FSA to asses the risks in the Danish market. .
Moreover, we want to highlight concerns regarding the scale of data points required. While some alignment exists with national questionnaires, many data points are not stored in distinct fields. Although for example the complexity of a structure is considered for the risk assessment of the client during onboarding or re-identification, this is not something that is separately recorded in the systems. Therefore, implementing this will require significant IT investments and considerable compliance costs.
This new massive burden seems to go against the ideas of the time to deregulate and lower administrative burdens for European countries eg. in the omnibus regulation.