Submission #28

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Austrian Federal Economic Chamber, Division Bank and Insurance

2. Do you have any comments on Guideline 4.1 ‘Internal policies and procedures’? If you do not agree, please set out why you do not agree and if possible, provide evidence of the adverse impact provisions in this section would have.

4.1.2 para 13: Approval by management body
We propose that an approval of the respective policy by the management body should not be mandatory. From our perspective it is sufficient that the CDD requirements as an integral part of an AML manual are approved by the management body.

8. Do you have any comments on the Guideline 4.7 ‘ICT and security risk management’? If you do not agree, please set out why you do not agree and if possible, provide evidence of the adverse impact provisions in this section would have.

Section 5: Accompanying Documents
Para 1: Governance arrangements
We plead for Option 1, i.e. that no governance arrangements should be included in the guidelines.
Para 2: Proportionality in Governance Arrangements
In case that governance arrangements would be included in the guidelines, wo would suggest that according to option 3 the assessments under eID solutions can be taken into account by obliged financial sector operators.
Para 3: Verification Process: Liveness detection
A mandatory liveness detection should be restricted to cases of high risk.

Name of the organization Austrian Federal Economic Chamber, Division Bank and Insurance