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Response to consultation on effective management of ML/TF risks when providing access to financial services
Go back6. Do you have any comments on the section titled ‘Complaint mechanisms’?
Bank of Valletta thanks the EBA for the opportunity to express our views on the proposed Guidelines. We would like to comment on the proposal under the Complaint Mechanism section. Whilst in principle we support education/guidance to exited customers on the channels available to them to register a complaint, it is important to mention that in the majority of the instances, the institution would not be able to divulge the reason for the exit, or defend its position in front of the Arbiter and/or other alternative dispute resolution bodies, because in doing so, the institution will be divulging highly sensitive information on the affairs of the exited customers, which may prejudice ongoing/future investigations by authorities and/or law enforcement agencies, whilst also breaching its obligations not to tip off customers. In our view, it will also expose the MLRO significantly and may impair the decision-making process of MLROs.Name of the organization
Bank of Valletta p.l.c
