ALFI responds to AMLA’s consultation on the draft RTS on Customer Due Diligence

In its response, ALFI underlines that the Draft RTS appears to have been conceived primarily from the perspective of retail banking and direct client relationships, and therefore advocates for the specificities of the European fund industry to be better taken into account. In particular, Article 17 on the Identification and verification obligations for collective investment undertakings should more adequately reflect the intermediated model, in which banks and other intermediaries invest on behalf of a multitude of underlying investors.

View the ALFI response.