In our consultation response we point out, among other things, the need for greater clarity about the relationship between the HIS, the Anti-Money Laundering Regulation (AMLR) and the Anti-Money Laundering Directive (AMLD). It is essential for institutions to be clear which obligations arise directly from European regulations and on which points the WIS is supplementary. We advocate adhering as closely as possible to the systematics and principles of the AMLR in order to avoid overlap, lack of clarity and unnecessary burdens for institutions.
Moreover, the consultation explicitly asks about the design of the national risk assessment (NRA). We advocate a primarily directive NRA that leaves room for a risk-based interpretation by institutions. We believe it is important for the NRA to be sufficiently sector-specific, so that examples, case histories and typologies are actually relevant and usable for the asset management sector. We also consider it important that the NRA focus primarily on inherent risks and not on institutions' pre-existing control measures.
