On 8th April, KYC 360 reported that the European Supervisory Authorities were mandated to produce guidance, as Regulatory Technical Standards (RTS), to assist groups address the issue.  The Standards sets out a number of measures that international firms must take, using a risk-based approach, where their branches and majority owned subsidiaries (units) operating in third countries cannot implement certain elements of group policies due to local legal impediments.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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