ML/TF risks and prudential concerns

When analysing the internal governance framework and institution-wide controls, competent authorities should also take into account the assessments received from AML/CFT supervisors and evaluate whether these give rise to prudential concerns. Conversely, where the competent authority’s assessment indicates the shortcomings in an institution’s internal controls and governance framework and institution-wide controls give rise to prudential concerns related to ML/TF risk and risks of non-implementation and evasion of targeted financial sanctions, competent authorities should share the outcome of that assessment with AML/CFT supervisors.

Competent authorities should assess whether the institution’s overall internal governance and risk management framework includes also the management of the ML/TF risks and the risks of non-implementation and evasion of targeted financial sanctions.

Competent authorities should assess from a prudential perspective whether the roles and responsibilities of the management body with regard to the AML/CFT framework are being complied with. Competent authorities should take into account any supplementary information received from the AML/CFT supervisors following their assessment in line with the EBA Guidelines on policies and procedures in relation to compliance management and the role and responsibilities of the AML/CFT Compliance Officer⁽³⁵⁾.