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On 10 April, BaFin (Bundesanstalt für Finanzdienstleistungsaufsicht – BaFin) issued a new Circular (Circular 03/2017) on anti-money laundering  (AML) related requirements of video identification procedure. BaFin states that the video identification procedure may be applied by all persons who are defined as obligated persons according to the German Money-Laundering-Act (GwG) and who are under the supervision of BaFin. Thus, in particular Capital Investment Management Companies may use the video identification procedure. Pursuant to Circular 04/2016…
On 31 March 2017, the German Federal Council announced its opinion that the government’s draft act for the implementation of the 4th EU Anti-Money-Laundering Directive (4th AMLD-Draft Implementation Act) requires several amendments. The 4th AMLD-Draft Implementation Act provides that the General Customs Administration (Generalzolldirektion) shall be the responsible administrative body for the investigation of financial transactions, and that it shall forward notices of suspicious money laundering behavior to the prosecuting authorities. The Council disagrees with…
On 8 March 2017 BaFin published an updated version of the MaComp Circular. The MaComp (Minimum Requirements for the Compliance Function and Additional Requirements Governing Rules of Conduct, Organisation and Transparency pursuant to Sections 31 et seq. of the Securities Trading Act (Wertpapierhandelsgesetz – WpHG) for Investment Services Enterprises) comprise all publications concerning the conduct of business rules set out in sections 31 et seq. of the WpHG. Module BT 3.2 and Module BT 5…
Our European financial services team will be hosting a series of seminars in November 2016 across our offices in France, Germany, Italy and the Netherlands. The seminars will focus on MIFID II and will cover: Update on the European legislative process including local implementation Highlights from the new conduct requirements Thoughts on the new market structures Other interesting issues around execution and post-trade More information and booking details for each seminar can be found via…