4. Programme of operations: information on AML/CFT requirements

In order to determine whether there are reasonable grounds to suspect that the TCB would be used to commit or facilitate the commission of ML/TF, the application should include the following:

• a) identity of the person responsible for the TCB’s compliance with AML/CFT requirements in the Member State in which it seeks authorisation;
• b) the business-wide ML/TF risk assessment of the TCB, having regard to the inherent risk factors relating to the nature and characteristics of its target customer bases, the products and services offered and distribution channels used;

25 The Consultation Paper is available at https://www.eba.europa.eu/publications-and-media/press-releases/eba-and-esma-launch-consultation-revised-suitability-assessment-framework-banks-and-investment-firms 26 Regulation (EU) 2022/2554 of the European Parliament and of the Council of 14 December 2022 on digital operational resilience for the financial sector and amending Regulations (EC) No 1060/2009, (EU) No 648/2012, (EU) No 600/2014, (EU) No 909/2014 and (EU) 2016/1011 (OJ L 333, 27.12.2022, p. 1, ELI: http://data.europa.eu/eli/reg/2022/2554/oj)

• c) description of the TCB’s governance arrangements and resources dedicated to its AML/CFT compliance function and the applicant’s assessment of the adequacy of those arrangements and resources in light of the inherent ML/TF risks which the TCB will be exposed to;
• d) description of the envisaged AML/CFT related internal systems and controls and how they respond to the ML/TF risks identified in the ML/TF risk assessment, referred above;
• e) description of the origin of the resources that constitute the capital endowment, and the channel used for the transfer of the instruments that will be part of the capital endowment.