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?
Although the majority of the data points requested are available to Nordea, many are not currently required as part of regulatory reporting requirements. There would therefore have to be an initial investment to establish the relevant framework, process and approvals for the new data points. An estimate of cost would be dependant on whether the reporting is required at entity or group level and whether any country specific data would be required. The set up cost would be circa EUR 1m and therefore close consideration should be given to whether the provision of such data points would benefit the fight against financial crime.
3b: Among the data points listed in the Annex I to this consultation paper, what are those that are not currently available to most credit and financial institutions?
To answer that question we would need to wait for the further detail to be provided in the "interpretive note" on the following categories and data points:
- Walk in customers definition
- Sub-category "Invest. Services and Activities - reception and transmission of orders"
- Sub-category "Money Remittance"
- Sub-category "Exchange crypto-fiat" - Is this only related to CASPs or financial institutions that provide crypto-fiat services? For an example a financial institution may not provide any crypto related services but customers holding crypto wallets could still perform crypto-fiat transfers.
- Category "Distribution Channels" - Further information and definition of agents and distributors required.