The proposed group-wide requirements do not always align well with the practices of asset managers operating internationally. Many asset managers operate under decentralized governance structures, combining global standards with local compliance frameworks, independent boards, and dedicated AML/CFT functions.
We also see key areas of concern regarding the exchange of information within groups. The draft RTS contain extensive obligations regarding the sharing of customer data, transaction data, and risk assessments. We therefore request greater clarity on the application of the “need-to-know” principle and its relationship to privacy, confidentiality, and data protection laws.
