GROUP-WIDE AML/CTF COMPLIANCE: NEW OBLIGATIONS FOR FIRMS WITH OVERSEAS BRANCHES AND SUBSIDIARIES?

In December 2017, the European Supervisory Authorities published a Report on draft Joint Regulatory Technical Standards (“RTS“) on the measures that credit and financial institutions should take to manage money laundering risk in their non-EU overseas branches and subsidiaries. The RTS focusses on the measures that EU firms must adopt when local law prevents their branches and subsidiaries sharing information with them for anti-money laundering purposes. To date, the draft RTS has received little attention, but it is potentially of significant importance to firms with branches and subsidiaries in non-EU jurisdictions with strict banking secrecy or data privacy requirements, as it may require them to adopt new monitoring strategies and arrangements. In this briefing we summarise the background to and requirements of the draft RTS.

Please click here to see our full briefing on this matter.

 

Susannah Cogman
Susannah Cogman
Partner
Email | Profile
+44 20 7466 2580
Daniel Hudson
Daniel Hudson
Partner
Email | Profile
+44 20 7466 2580
Elizabeth Head
Elizabeth Head
Senior associate
Email | Profile
+44 20 7466 2470

Leave a Comment

Filed under Bribery and Corruption, EU, European Regulation, Sanctions and Money Laundering, Sector Updates by Herbert Smith Freehills

Leave a Reply