September 1 2016
Comments on the European Commission proposal for a directive amending the Fourth Anti-Money...
The German Banking Industry Committee (GBIC) would like to take the reopened debate on creation of an optimal anti-money laundering and counter-terrorist financing (AML/CFT) framework as an opportunity to input its own experience and ideas.Mehr
August 31 2016
Comments on Notice 2016-42 (proposed changes to qualified intermediary agreements)
The new rules in section 5.03(B) of the proposed QI agreement provide that the LOB declaration (which may be used by entities that are not fiscally transparent to document their status together with “alternative” documentary evidence.Mehr
June 3 2016
Comments on Consultative Document on Standardised Measurement Approach for Operational Risk (BCBS...
In autumn 2015, the BCBS announced that it would withdraw the AMA for operational risk. It stated that the rationale for dropping the AMA would be explained in the BCBS’s new consultative document. In our view, however, the consultative document does...Mehr