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ESAs Publish Draft Group AML Risk RTS

The ESAs have published draft RTS under MLD4 on how credit and financial institutions should manage their AML/TF risks at group level where their group includes branches or major subsidiaries in third countries that do not permit group wide policies to be used. The RTS include practical steps institutions should take, such as:

  • getting customer consent to data sharing and processing

  • carrying out reviews to be satisfied the branches can properly assess and manage ML/TF risks

  • restricting the offerings of products and services to low-risk ones, and requiring senior management approval for anything else

  • restricting the ability to rely on CDD carried out by those entities.

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About this Author

Emma Radmore, Womble Dickinson Law Firm, United Kingdom, Finance Law Attorney
Legal Director

Emma joined the firm in August 2016. She has over 20 years' experience of specialising in financial services regulation. Emma advises UK and international clients on compliance with all aspects of financial regulation and prevention of financial crime.

Emma acts for a range of regulated clients including banks, fund managers, investment firms, insurance firms and other retail intermediaries.

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