Response to consultation on draft Guidelines under Articles 17 and 18(4) of Directive (EU) 2015/849 on customer due diligence and ML/TF risk factors
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Question 1: Do you have any comments with the proposed changes to the Definitions section of the Guidelines?
Please see the attached response letter.Question 2: Do you have any comments on the proposed amendments to Guideline 1 on risk assessment?
Please see the attached letter.Question 3: Do you have any comments on the proposed amendments to Guideline 2 on identifying ML/TF risk factors?
Please see the attached letter.Question 4: Do you have any comments on the proposed amendments and additions in Guideline 4 on CCD measures to be applied by all firms?
Please see the attached letter.Question 7: Do you have any comments on the amendments to Guideline 7 on reviewing effectiveness?
Please see the attached letter.Question 8: Do you have any comments on the proposed amendments to Guideline 8 for correspondent banks?
Please see the attached letter.Question 18: Do you have any comments on the additional sector-specific Guideline 18 on account information and payment initiation service providers?
Please see the attached letter.Upload files
IIF Response EBA ML TF Consultation Final.pdf
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