Response to consultation on effective management of ML/TF risks when providing access to financial services
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Is this Guideline Mandatory for smaller financial institutions?
Regarding this rule - should we disclose the reason to the customer who has been denied the service or with whom we have terminated the business relationship with?
For our corresponding bank: if our bank which keeps the customers' money in a client account, may require documents in order to accept and send money out. Should this situation occur when the customer is unable to provide a traditional document (because they are either a refugee or a vulnerable customer), should the services to the customer be denied or postponed until CDD can be fulfilled either by the customer at a later stage. This is depending on if the corresponding bank refuses to accept the alternatives.
1. Do you have any comments on the annex that covers NPO customers?
NA2. Do you have any comments on the section ‘Subject matter, scope and definitions’? 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.
Does the Guideline apply to investment services overall, e.g. trading and investment services either in stocks, bonds, crowdfunding, p2p lending investments etc?Is this Guideline Mandatory for smaller financial institutions?
3. Do you have any comments on the section titled ‘General requirements’?
"Credit and financial institutions should document any decision to refuse or terminate a business relationship and the reason for doing so. Furthermore, they should be prepared to make this documentation available to their competent authority upon request."Regarding this rule - should we disclose the reason to the customer who has been denied the service or with whom we have terminated the business relationship with?
4. Do you have any comments on the section titled ‘adjusting monitoring’?
For Refugees and Vulnerable customers who are unable to provide traditional documents, such as valid ID cards. In this case, should a rental agreement or a utility bill be sufficient to prove residence?For our corresponding bank: if our bank which keeps the customers' money in a client account, may require documents in order to accept and send money out. Should this situation occur when the customer is unable to provide a traditional document (because they are either a refugee or a vulnerable customer), should the services to the customer be denied or postponed until CDD can be fulfilled either by the customer at a later stage. This is depending on if the corresponding bank refuses to accept the alternatives.