FS Regulatory Insights: September 2017 | KPMG | BH
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FS Regulatory Insights: September 2017

FS Regulatory Insights: September 2017

It has been a busy summer as regulators have been publishing numerous regulatory updates over the holiday period.


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It has been a busy summer as regulators have been publishing numerous regulatory updates over the holiday period.

The three European Supervision Authorities (ESAs) have finalised their Anti-Money Laundering (AML) guidelines on how financial institutions can take a more risk-based approach to AML and countering the financing of terrorism, under the Fourth AML Directive. These guidelines are helpful in setting out the factors that may influence whether a client could be subject to SDD (Simplified Customer Due Diligence), or indeed will require EDD (Enhanced Due Diligence). The Financial Action Task Force (FATF) has concluded its assessment of Ireland’s anti-money laundering and counter-terrorist financing (AML/CFT) system and has issued a favourable report. Transposition of the Fourth AML Directive into Irish Law has yet to be completed and is expected in early 2018.

We look at the implications of the Financial Stability Board (FSB) FinTech report, published at the end of June, highlighting ten issues that merit the attention of supervisors and regulators, of which the first three are put forward as priority areas for international cooperation.

In MiFID II news, ESMA has said it does not expect to release the final guidelines until the first half of 2018, after the implementation deadline of 3 January 2018. We look at the demanding position this leaves firms in. Continuing with cross-sector updates, the ESAs have issued the first set of Q&As relating to the PRIIPs Key Information Document (‘KID’). With the imminent end-2017 deadline for implementation, we discuss how firms must continue to work towards this target, and the effective earlier deadline for PRIIPs invested in by other PRIIPs. We also break down the key points of latest three guidance documents relating to the joint work plan on CCP resilience, recovery and resolvability.

In asset management, IOSCO has continued its dialogue on liquidity risk management in investment funds, and has issued its report on progress made in the protection of client assets.

And in banking, our European Central Bank office has published a report on what the long term prospects of the European banking sector are, in the light of the ECB’s report on financial structures.

As always, we want to hear your feedback, so please contact me or a member of the team whose details are below.

In this issue

  • Move to centralised regulation of EU funds and delegation arrangements
  • IOSCO reports on progress in the protection of assets 
  • IOSCO consults on liquidity risk management in investment funds
  • ESMA guidelines on MiFID II suitability requirements expected in 2018 
  • CCP resilience, recovery and resolvability 
  • Detailed requirements for the PRIIP KID begin to emerge 
  • FinTech risks 
  • AML Guidelines

Previous editions

  • FS Regulatory Insights - August 2017
  • FS Regulatory Insights - July 2017
  • FS Regulatory Insights - June 2017
  • FS Regulatory Insights - May 2017

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