EBF advisor: Roger Kaiser
Publication date: 17 August 2018
The EBF welcomes the opportunity to provide comments on the FATF Public Consultation on the Draft Risk-Based Approach (RBA) Guidance for the Securities Sector. The EBF suggests that the Guidance distinguishes its standards per (i) type of service/ service provider, (ii) type of security and (iii) type of customer/ relationship. Regarding relationships similar to Correspondent Banking Relationship (CBR) in case of intermediaries, the EBF recommends FATF to highlight that not all CBRs pose the same level of risk. Therefore, securities providers should adjust the type and extent of Enhanced Due Diligence measures to account for the risk posed by the respondent.