EBF comments on the draft RBA guidance for the securities sector

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 and has several suggestions.

The EBF suggests that the Guidance distinguishes its standards per

• type of service/ service provider,
• type of security and
• 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.

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