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FATF Risk-based Approach

Lobbying and defending the interests of our members is at the very core of our what we do in LIMSA. Recently we were asked by the ABBL to give an opinion to the FATF on the Public Consultation on the Draft Risk-Based Approach Guidance for Trust and Company Service Providers, a subject very relevant to our business. We responded by immediately setting up a Compliance Working Group consisting of a broad section of our members. The Working Group expressed its views and a letter was drafted and sent to the FATF.

In an attempt to accommodate and be relevant to all forms of TCSPs and the various regulatory/supervisory regimes that they operate under globally, the guidance as ultimately drafted is very high level and simply a reflection of the standards to which we and our principal regulators already adhere to. That being said there were three points regarding Due Diligence and the “Nominee Director” concept that we highlighted and commented on.

As the TCSPs' consultation of the FATF was also subject to consultation by the European Banking Federation ("EBF"), to which ABBL is a member, ABBL asked us if LIMSA’s opinion could also be submitted to the EBF. The final version of the guidelines was issued on 26 June and were encouraged to see that certain of our points had been addressed and the relevant paragraphs had been duly amended.

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