Posted by Brian Monroe - firstname.lastname@example.org 08/13/2021
On heels of EU AML overhaul, EBA releases draft guidance, expectations for compliance officers, requirements for pan-bloc oversight, accountability, authority
Don’t get tripped up with new, updated terminologies: Official offices, officer duties
The strengthened EU AML guidelines focus on more forcefully deputizing certain fincrime compliance officers, and others, at varying levels of the organization, with particular attention paid to large banking groups working across the bloc – and beyond.
Here is a glimpse of some of the key terms:
AML/CFT Compliance officer
This is the person at the top of the AML hierarchy, responsible for ensuring compliance with regional fincrime compliance directives, and now, the stronger EU-wide initiatives.
Groupwide AML officer
Under current EU AML rules, the institution is charged with effectively mitigating ML/TF risks at both entity level and group level.
Where a financial services operator is part of a group, a Group AML/CFT compliance officer in the parent company should be appointed to ensure the establishment and implementation of effective group-wide AML/CFT policies and procedures – an update under one of the refreshed guidelines.
The management body and/or senior manager in charge of AML/CFT compliance
This could be the chief compliance officer, or similar high-level individual with authority to communicate laterally, to other C-suite executives, about the needs of the AML team – potentially budget decision-makers – and take concerns, fears and failings upward to the board of directors.
Management body in its supervisory function
Means the management body acting in its role of overseeing and monitoring management decision-making.
Management body in its management function
Means the management body responsible for the day-to-day management of the financial sector operator.
These are the member state regulators having oversite of banking groups in their jurisdiction
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