FTS submitted feedback to the European Banking Authority (EBA) recently as part of their invitation for public comment on its Proposed Regulatory Technical Standards, as part of the EU’s evolving AMLA mandates.
A total of 108 institutions and companies provided feedback.
We attach here our comments, this time WITH DIAGRAMS – which were not possible to include in the EBA format.
On review of the draft methodology:
Strix is well aligned with the proposed methodology. From the level of detail provided thus far by EBA, the new methodology appears to be easily accommodated in Strix as simply another of our offered calculation methods available (AMLA will be the 4th method captured in Strix).
There are many aspects of Strix that make it fit-for-AMLA, and EU authorities specifically would benefit from a ready-to-go solution given the timelines to implement thus far indicated by EBA.
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