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The Consultation paper published on July 29 by the European Banking Authority (EBA), invites comments on all proposals listed below.


The role and responsibilities of the management body in the AML/CFT framework and of the senior manager responsible for AML/CFT.

This section sets out EBA’ expectations regarding the role and responsibilities of financial sector operators’ management body relating to the:

  • Approval of the policies, controls and procedures

  • Role of the management body in its supervisory function in the AML/CFT framework

  • Role of the management body in its management function in the AML/CFT framework

  • Identification of the member of the management body responsible for AML/CFT

  • Identification of a senior manager responsible for AML/CFT where no management body is in place

  • Tasks and role of the member of the management body or senior manager responsible for AML/CFT

Role and responsibilities of AML/CFT compliance officer

This section includes EBA’ proposed guidelines relating to the following:

  • Appointment of the AML/CFT compliance officer

  • Proportionality criteria for the appointment of a separate AML/CFT compliance officer

  • Suitability, skills and expertise of the compliance officer

  • Tasks and role of the AML/CFT compliance officer

  • Relationship between AML/CFT compliance function and other functions

Organisation of AML/CFT compliance function at group level

EBA’ proposed guidelines this section focuses on the following:

  • Integration at group level

  • Role of the management body for AML/CFT at group level

  • Organisational requirements at group level

Review of AML/CFT compliance function by competent authorities

Including the proposal that competent authorities ensure that AML/CFT compliance officers meet the conditions relating to integrity, expertise and knowledge of the legal and regulatory AML/CFT framework, either at appointment or at a later stage.

Responses to this consultation will help the EBA address the uneven implementation of AML/CTF rules across the EU for more efficiency in the results sought in fighting financial crime.

The draft guidelines are published for a three-months public consultation.

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