81. The group AML/CFT compliance officer should have at least the following tasks: a) coordinate …

The group AML/CFT compliance officer should have at least the following tasks:

• a) coordinate the business-wide assessment of the ML/TF risks carried out at local level by entities of the group and organise the aggregation of their results in order to have a good understanding of the nature, intensity and location of the ML/TF risks to which the group as a whole is exposed;
• b) draft a group-wide ML/TF risk assessment. In this respect, the parent entity of the group should take into account, in its ML/TF risk management system at group level, both the individual risks of the various entities of the group and their possible interrelations that could have a significant impact on the group-wide risk exposure. In this respect, particular attention should be paid to the risks to which the group ’ s branches or subsidiaries established in third countries are exposed, especially if they are of high ML/TF risk;
• c) define group-level AML/CFT standards and ensure that local, entity-level policies and procedures comply with the AML/CFT legislation and regulations applicable to each entity of the group individually, and are also aligned to the group standards defined;
• d) coordinate the activities of the various local AML/CFT compliance officers in the group's operational entities in order to ensure that they work consistently;
• e) monitor compliance of the branches and the subsidiaries located in third countries with EU AML/CFT provisions, in particular where requirements for the prevention of ML/TF are less strict than those set out in Directive (EU) 2015/849²⁸ ;
• f) set group-wide policies, procedures and measures concerning, in particular, data protection and sharing of information within the group for the purposes of AML/CFT, in accordance with the national legal provisions;
• g) ensure that the entities of the group have adequate STRs procedures and share information properly, including the information that a suspicious transaction report has been filed (with no prejudice to national confidentiality rules where existing).

²⁸ Please also refer to the Joint ESA Regulatory Technical Standards on the implementation of group-wide AML/CFT policies in third countries of 6 December 2017: JC 2017 25

1. Overview

1.1 References

1.2 Identified Requirements

1.3 Related Standards

2. Identified Requirements

3. Related Standards

• EBA - Published by the European Banking Authority at https://www.eba.europa.eu/