Its main question is whether the good practices document is sufficiently clear and offers effective guidance that allows banks to meet the statutory requirements for managing tax-related and other integrity risks.
1. Good practices
To prepare the good practices document, we drew on the key findings from our thematic examination “Aggressive tax planning and customer anonymity” from 2017. The document thus provides examples of how you could identify tax integrity risks in your customer portfolio and how this is related to your integrity risk appetite. In addition, it provides practical examples of due diligence investigations into individual customers and their transactions that pose increased risks.
2. Submitting comments
We are inviting not only banks to submit their comments, but also consultants and service providers that support banks in their compliance. Please feel free to submit your comments no later than 1 April 2019. You will find more information on our Open Book on Supervision pages.
3. Questions and contact
If you have any questions regarding the content of these good practices or the possibility to submit comments please contact the following examining officers of the Expert Centre Integrity Strategy:
- Olivier Houppermans, email: firstname.lastname@example.org
Axel Gospodinov, email: email@example.com
4. Processing of consultation responses
We will start processing stakeholder responses after 1 April 2019 and publish the final version of the good practices document on our website.