On February 6, 2020, BPI submitted a comment letter to the Basel Committee on Banking Supervision (BCBS) in response to the Committee’s consultative document titled, “Introduction of guidelines on interaction and cooperation between prudential and AML/CFT supervision”. In its letter, BPI recommends that the consultative document be modified to affirmatively state that AML supervisory expectations should solely reflect the legal and regulatory framework of a jurisdiction, and should be structured to provide highly useful information to law enforcement with increased law enforcement engagement in the supervisory and rulemaking process. BPI also encouraged the BCBS to include provisions to provide appropriate notice to financial institutions when information is being shared between supervisors, in an effort to mitigate the risk of a regulator unfamiliar with a given institution misinterpreting the information being shared.
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