PwC Regulatory Update

September 2018

www.pwc.com.au

1Legislative/Government developments

The Royal Commission into Misconduct in the Banking, Superannuation and Financial Services Industry (Royal Commission) – release of Interim Report and upcoming seventh round

The Royal Commission continues with the seventh round of hearings which will take place from 19 - 30 November 2018. The focus will be on policy questions arising from the first six rounds of hearings.

The Interim Report was submitted to the Governor-General on 28 September 2018. Public submissions in response to the Interim Report are due by 5pm on 26 October 2018. The final report will be submitted to the Governor-General by 1 February 2019.

Several industry bodies have released responses to the Interim Report:

• The Financial Services Council’s (FSC) responded by urging the financial services industry to prioritise the best interests of consumers;

• The Australian Banking Association (ABA) stated that banks have accepted responsibility for their failures and are working to earn back the trust of the public. The industry will respond to specific findings from the Interim Report in the coming weeks, and by 26 October at the latest; and

• The Customer Owned Banking Association’s (COBA) responseemphasised the importance of placing the customer above profit.

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What have the regulators been up to?

Overseas developments

Industry bodies

PwC publications

Legislative/Government developments

Contacts

1Legislative/Government developmentsThe Government seeks consultation on various bills and regulations

The Government is seeking feedback on the second stage of exposure draft legislation for the Treasury Laws Amendment (Consumer Data Right) Bill 2018. The legislation reflects the Government’s commitment to implementing the Consumer Data Right (CDR) in line with the recommendations of the Review into Open Banking in Australia. The revised sections of the exposure draft legislation include the following measures:

• Limiting the scope of the legislation in regards to rule-making powers requiring access to derived data;

• Clarifying the interaction of the Privacy Safeguards with the Privacy Act; and

• Clarifying the operation of reciprocity.

Submissions are due by 12 October 2018.

See media release

The Government is seeking feedback on the proposed Financial Sector (Transfer and Restructure) Regulations 2018 and the Australian Prudential Regulation Authority Regulations 2018. The proposed changes to regulation will repeal the existing Financial Sector (Transfers of Business) Regulations 1999 and Australian Prudential Regulation Authority Regulations 1998, and are due to become effective on 1 April 2019. The purpose of the changes are to align with current drafting practices and enhance the operation of regulations without altering the substantive meaning of the provisions.

Submissions are due by 23 October 2018.

See media release

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What have the regulators been up to?

Overseas developments

Industry bodies

PwC publications

Legislative/Government developments

Contacts

The Government is seeking feedback on draft legislation; Treasury Laws Amendment (ASIC Enforcement) Bill 2018, to strengthen penalties for corporate and financial sector misconduct. The legislation seeks to:

• Update the penalties for certain criminal offences in ASIC-administered legislation;

• Introduce ordinary criminal offences that sit alongside strict and absolute liability offences;

• Increase the financial penalties significantly for civil contraventions; and

• Harmonise and expand the infringement notice regime.

Submissions are due by 23 October 2018.

See media release

The Government is seeking feedback on draft legislation; Commonwealth Registers Bill 2018, and Treasury Laws Amendment (Registries Modernisation and Other Measures) Bill 2018, to modernise Business Registers. The amendments proposed under the legislation include:

• Allowing continuous flexibility to the appointed Registrar or Registrars to adapt to technology changes;

• Core provisions to facilitate a modern government registry regime; and

• A legal framework for the introduction of Director Identification Numbers (DINs), including details such as the requirement to obtain a DIN and its obligations, the consequences of not meeting those obligations and how DINs will be administered.

Submissions are due by 26 October 2018.

Source: Treasury

2What have the regulators been up to?

APRA publishes new prudential standards and guides to strengthen governance in the Private Health Insurance (PHI) industry

APRA has published three new prudential standards and two prudential guides to enhance governance in the PHI industry.

The new prudential standards for the PHI are:

• Prudential Standard CPS 510 - Governance, a robust cross-industry standard on board governance and renewal;

• Prudential Standard CPS 520 - Fit and Proper, requiring boards to establish and apply a written policy to ensure the competence and integrity of anyone exercising material influence over the company; and

• Prudential Standard HPS 310 - Audit and Related Matters, requiring companies in the PHI to appoint an auditor to provide independent advice on their operations, financial position and risk controls.

APRA has also released two prudential practice guides, Prudential Practice Guide HPG 510 - Governance and Prudential Practice Guide HPG 520 – Fit and Proper, to help the PHI meet the requirements of the three new standards. The revised prudential standards will come into effect from 1 July 2019.

See media release

APRA publishes Information Paper on outsourcing involving cloud computing services

APRA has published an Information Paper; Outsourcing involving cloud computing services, which updates information on prudential considerations and key principles to be considered by APRA regulated entities when using cloud computing services.

The paper has been released in response to the growing usage of cloud computing services and the subsequent improvement in the ability of APRA-regulated entities to manage the associated risks.

See media release

– 4 –

What have the regulators been up to?

Overseas developments

Industry bodies

PwC publications

Legislative/Government developments

Contacts

APRAAustralian Prudential Regulation Authority

ASICAustralian Securities and Investments Commission

ASXAustralian Securities Exchange

RBAReserve Bank of Australia

2What have the regulators been up to?Recent reports

ASIC has released a report, Insurance in Superannuation, following their review of the insurance cover provision through superannuation by 47 superannuation trustees. The review focused on:

• Insurance claims and complaints handling;

• Disclosures about insurance (including cover ceasing);

• Insurer rebates paid to trustees; and

• Whether members were defaulted into demographic categories that resulted in higher premiums.

The review identified actions to be taken by trustees to deliver better outcomes for members who acquire life insurance coverage through their superannuation funds.

ASIC has also released a report, Review of selected financial services groups’ compliance with the breach reporting obligation, setting out the findings from their review of AFS licensees’ compliance with their breach reporting obligation under s912D of the Corporations Act 2001. The intention of the review was to assess the adequacy and effectiveness of breach reporting, compliance with breach reporting obligations and demonstration of a sound breach-reporting culture in selected financial services groups.

The Financial Services Council (FSC) has expressed support for ASIC’s recommendation to introduce civil penalties for organisations failure to report breaches within required timeframes. FSC CEO Sally Loane stated: “More than ever, financial institutions need to embrace a sense of urgency to respond to incidents so that consumers can have wrongs put right as soon as possible”.

The CEO of the ABA, Anna Bligh said that the report was another wake up call for banks to lift their game in quickly fixing issues in their business.

ASIC releases new regulatory guides for wholesale equity schemes and compliance schemes for financial advisers

ASIC has released RG 192 - Licensing: Wholesale equity schemes, the updates under RG 192 are applicable to trustees of wholesale equity schemes that are operated by a manager holding an Australian Financial Services (AFS) licensee. RG 192 sets out:

• The licensing relief provided in ASIC Corporations (Wholesale Equity Scheme Trustees) Instrument 2017/849 for trustees of wholesale equity schemes that are operated by a manager of an AFS; and

• The amendments to financial requirements that may apply to these managers made by ASIC Corporations (Amendment and Repeal) Instrument 2017/848.

ASIC has released RG 269 - Approval and oversight of compliance schemes for financial advisers, outlining its approach to approving and overseeing compliance schemes applicable to financial advisers. RG 269 sets out:

• Processes and criteria for determining whether to grant approval to a compliance scheme;

• Expectations for the governance and administration, monitoring and enforcement processes, and ongoing operation of compliance schemes;

• ASIC’s powers to revoke the approval of a compliance scheme and to impose or vary conditions on the approval; and

• Notifications that monitoring bodies must make to ASIC.

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What have the regulators been up to?

Overseas developments

Industry bodies

PwC publications

Legislative/Government developments

Contacts

APRAAustralian Prudential Regulation Authority

ASICAustralian Securities and Investments Commission

ASXAustralian Securities Exchange

RBAReserve Bank of Australia

2What have the regulators been up to?ASIC has released a consultation paper, Remaking ASIC class order on share and interest purchase plans, and is seeking feedback on its proposal to remake the Class Order [co 09/425] Share and interest purchase plans, which is due to expire on 1 October 2019. Specifically, ASIC is seeking feedback on:

• Whether the class order is currently operating effectively and efficiently; and

• Whether the conditions of relief should remain unchanged.

Submissions are due by 2 November 2018.

Other key updates

ASIC has released a new instrument ASIC Corporations (Group Purchasing Bodies) Instrument 2018/751 to replace Class Order [CO 08/1], Group purchasing bodies, which was due to expire on 1 October 2018. The purpose of this is to continue exempting certain groups who purchase products to cover other people’s risks from being required to hold an AFS licence and other regulatory requirements.

ASIC has released a new instrument, ASIC Corporations (Amendment) Instrument 2018/807, to extend licensing relief for foreign financial services providers to help them provide financial services without needing to hold an AFS licence until 30 September 2019. The previous instruments expired in September 2018.

ASIC has released a new instrument, ASIC Corporations (Amendment) Instrument 2018/825, to extend the existing relief from managed investment and associated provisions to operators of employee redundancy funds under the Corporations Act 2001 (Corporations Act) until 1 October 2021.

As part of its role in overseeing the operation of the AFCA scheme, ASIC has approved the Australian Financial Complaints Authority (AFCA) complaint resolution scheme rules and the terms of reference of the AFCA Independent Assessor (IA). All financial firms including most credit representatives must join the AFCA scheme by 21 September 2018.

ASIC has prescribed a three-year period to be used by banks and credit providers when assessing a new credit card contract or credit limit increase under existing credit card contracts, after receiving feedback from its consultation paper, Credit cards: Responsible lending assessments.

ASIC has taken action to stop several proposed initial coin offerings and crypto-asset funds targeted at retail investors. ASIC could identify several problems, posing material risk for investors, including:

• The use of misleading or deceptive statements in sales and marketing materials;

• Operating an illegal unregistered managed investment scheme; and

• Not holding an AFS licence.

ASIC has released an updated regulatory guide, Managed discretionary accounts, stating that all Managed Discretionary Account (MDA) providers must hold an AFS licence, with an MDA-specific ‘dealing by issue’ licence authorisation.

– 6 –

What have the regulators been up to?

Overseas developments

Industry bodies

PwC publications

Legislative/Government developments

Contacts

APRAAustralian Prudential Regulation Authority

ASICAustralian Securities and Investments Commission

ASXAustralian Securities Exchange

RBAReserve Bank of Australia

2What have the regulators been up to?

ASX responds to consultation

The ASX has released its response to consultation on the proposed amendments to the ASX Settlement Operating Rules and ASX Clear Operating Rules and Procedures related to:

• The removal of the registered holder collateral cover authorisation form; and

• Enabling third party security interest over collateral and excess cash where the parties agree between themselves in writing that ASX’s security interest has priority.

The above amendments will be effective from 1 March 2019.

The ASX has released its response to consultation sought on the decision for a Distributed Ledger Technology (DLT) based system to underpin the replacement of CHESS. A total of 41 submissions were received, representing the views of a broad range of stakeholder groups. The feedback was broadly supportive of the ASX’s approach to updating Australia’s equity post-trade infrastructure and expressed a desire to better understand the potential benefits offered by the DLT based system.

The ASX has released its response to consultation on management of the ASX market, noting that they will be considering:

• Moving ASX Trade to the Adjust session state during a technical issue or outage, once certain conditions are satisfied;

• Options to meet participant requirements in relation to functionality;

• Providing at least 30 minutes notice in case the market opening need to be delayed;

• When possible giving 20 minutes notice prior to Pre-Open and 20 minutes of Pre-Open prior to resumption of trading;

• Further investigating ways to simplify the opening process;

• Halting the entire market if an equity subset has an error; and

• Continuing to transfer orders from the old code to the new code.

See media release

– 7 –

What have the regulators been up to?

Overseas developments

Industry bodies

PwC publications

Legislative/Government developments

Contacts

APRAAustralian Prudential Regulation Authority

ASICAustralian Securities and Investments Commission

ASXAustralian Securities Exchange

RBAReserve Bank of Australia

2What have the regulators been up to?

Assessment of ASX Clearing and Settlement Facilities

The Reserve Bank of Australia (RBA) has published a report, Assessment of ASX Clearing and Settlement (CS) Facilities, presenting its annual assessment of the ASX clearing and settlement (CS) facilities, in accordance with its obligations under the Corporations Act 2001. ASX operates two central counterparties (CCPs) and two securities settlement facilities (SSFs). The report details the CCPs and SSFs compliance with the Bank’s Financial Stability Standards for Central Counterparties (CCP standards) and Financial Stability Standards for Securities Settlement Facilities (SSF Standards), along with the Financial Stability Standards (FSS), as well as the facilities general obligation to do all things necessary to minimise systematic risk. The assessment identified that the CS facilities ‘observed’ or ‘broadly observed’ all relevant requirements under the FSS as at 30 June, except for the Operational Risk Standard, which was rated as ‘partly observed’.

The assessment includes:

• An update on progress made towards previous priorities;

• Recommendations for the facilities to either observe or continue to observe the requirements under FSS; and

• Priorities for the next assessment year to strengthen the facilities’ risk management arrangements.

See media release

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What have the regulators been up to?

Overseas developments

Industry bodies

PwC publications

Legislative/Government developments

Contacts

APRAAustralian Prudential Regulation Authority

ASICAustralian Securities and Investments Commission

ASXAustralian Securities Exchange

RBAReserve Bank of Australia

3 Industry bodies

The Association of Superannuation Funds of Australia’s (ASFA) submission to the Royal Commission recognises the Commission’s role in bringing to light areas of industry misconduct and regulatory weaknesses

In its submission to the Royal Commission, the ASFA recommended enhancing regulatory frameworks and developing stronger conflicts management through:

• Ending grandfathered trailing commissions paid to financial planners;

• Allowing the regulator to impose a sanction for a failure to act in the best interests of members; and

• Clearer demarcations in governance structures of trustee boards and related parties.

See media release

New Banking Code of Practice

The Australian Banking Association (ABA) has made a recommendation to the Royal Commission that the new Banking Code of Practice (the Code), recently approved by ASIC, should be adopted across the entire industry and include banks which are not members of the ABA, including credit unions and other lenders, to safeguard consumer protections. The new Code will be fully implemented by 1 July 2019.

Initiatives in the new Code include:

• Customer reminders when introductory credit card offers are about to end;

• New measures to assess a customer’s ability to repay their credit card limit within five years;

• Proactive contact with customers deemed at risk of financial difficulty and have measures to help them;

• Simplified loan contracts;

• Better protections for guarantors to ensure they understand their obligations; and

• A new independent body to investigate breaches and apply sanctions where necessary.

See media release

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– 9 –

What have the regulators been up to?

Overseas developments

Industry bodies

PwC publications

Legislative/Government developments

Contacts

ABAAustralian Banking Association

ASFAThe Association of Superannuation Funds of Australia

COBACustomer Owned Banking Association

4Overseas developments –Global

BIS: Recent announcements IOSCO: Recent announcements IOSCO: Recent announcements

The Basel Committee on Banking Supervision (BCBS) met to discuss a range of policy and supervisory issues, which included:

• Annual assessment results for Global Systemically Important Banks (G-SIBs);

• Progress on revising the market risk framework and implementation;

• Leverage ratio impact on client clearing;

• Views on emerging conjunctural and structural risks; and

• Further work on banks' crypto-asset exposures.

Source: BIS

The International Organisation of Securities Commissions (IOSCO) Board has released a report on Retail OTC Leveraged Products, identifying regulatory approaches to enhance the protection of retail investors.

IOSCO has developed three complementary toolkits to assist IOSCO members on ways to protect retail investors that have been offered OTC leveraged products, often on a cross-border basis. These toolkits set out:

• Policy measures and guidance for regulating the offer and sale of OTC leveraged products by intermediaries;

• Educating investors about the risks of OTC leveraged products and the firms offering them; and,

• Enforcement approaches and practices to mitigate the risks posed by unlicensed firms offering the relevant products to retail investors.

Source: IOSCO

The IOSCO Board has released a report, Conflicts of interest and associated conduct risks during the equity capital raising process. The report sets out the guidance for regulators to address conflicts of interests and misconduct risk when managing equity security offerings.

Source: IOSCO

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What have the regulators been up to?

Overseas developments

Industry bodies

PwC publications

Legislative/Government developments

Contacts

4Overseas developments –Europe

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What have the regulators been up to?

Overseas developments

Industry bodies

PwC publications

Legislative/Government developments

Contacts

EBA: Recent announcements ESMA: Recent announcements ESMA: Recent announcements

The European Banking Authority (EBA) has published two reports:

• EBA report on Funding Plans analysing EU banks’ funding plans submitted to the EBA and the assessment on their feasibility

• EBA report on Asset Encumbranceanalysing an increasing level of asset encumbrance driven by decreasing levels of total assets.

The three European Supervisory Authorities (ESAs) – EBA, European Insurance and Occupational Pensions Authority (EIOPA) and European Securities and Markets Authority (ESMA) have published the results of their monitoring exercise on automation in financial advice. It indicates that while the overall number of firms and customers involved in the phenomenon of automation is quite limited, the automation in financial advice is slowly growing. The ESAs believe no action is required immediately, given that the identified risks have not yet materialised.

Source: EBA

The ESMA has agreed to renew the restriction on the marketing, distribution or sale of Contracts for Differences (CFDs) to retail clients from 1 November 2018. These restrictions include:

• Leverage limits on the opening of a position by a retail client;

• A margin close out rule on a per account basis;

• Negative balance protection on a per account basis;

• A restriction on the incentives offered to trade CFDs; and

• A standardised risk warning.

Source: ESMA

The ESMA has released two new completeness indicators for trading venues. They detail the delivery of Double Volume Cap (DVC) and bond liquidity data. The indicators are:

• Completeness Ratio, an indicator that provides information on the completeness of a particular venue, irrespective of the performance of other venues.

• Completeness Shortfall, an indicator that measures a venue’s performance in terms of completeness compared to other trading venues.

The DVC data indicator was published on 8 October and the bond liquidity indicator will be published by 1 November 2018.

Source: ESMA

4Overseas developments –UK

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What have the regulators been up to?

Overseas developments

Industry bodies

PwC publications

Legislative/Government developments

Contacts

Bank of England: Recent announcements

PRA: Recent consultations PRA: Recent consultations

The Bank of England’s Money Markets Committee (MMC), comprised of market participants from various financial and non-financial institutions, have released a public register displaying over 100 market participants’ Statements of Commitment to the UK Money Markets Code.

The Code sets out the standards and best practice expected from participants in the deposit, repo and securities lending markets, thereby promoting the integrity and effective functioning of these markets.

Source: Bank of England

The Prudential Regulatory Authority (PRA) has issued a consultation paper, Strengthening accountability: implementing the extension of the SM&CR to insurers. The PRA is seeking feedback on proposed rules relating to the extension of the Senior Managers and Certification Regime (SM&CR) to insurers.

The proposal includes technical changes to the status of those individuals related to the ‘current approved person approval’ who will be in a ‘designated senior management function’.

Submissions are due by 17 October 2018.

Source: PRA

The PRA also released consultation paper, Regulatory reporting: European Banking Authority Taxonomy 2.9, and is seeking feedback on changes to update reporting requirements. This is a result of EBA’s proposals to update the Implementing Technical Standards on Supervisory Reporting (Supervisory Reporting ITS).

The proposals cover existing PRA reporting templates for ring-fenced banks, statement of profit and loss, and forecast capital data.

Submissions are due by 12 December 2018.

Source: Bank of England

4Overseas developments –US

CFTC: Recent announcements OCC: Recent announcements SEC: Recent announcements

The US Commodity Futures Trading Commission (CFTC) and Monetary Authority of Singapore have signed a Memorandum of Understanding to help FinTech companies to expand into each other’s markets by collaborating on joint research projects, information exchange, mutual consultations and expertise sharing.

Source: CFTC

The Office of the Comptroller of the Currency (OCC) is seeking feedback on its proposed rule to provide flexibility to federal savings associations by implementing the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA). The Act requires the OCC to issue regulations to allow federal savings associations to operate with national bank powers, if they have total consolidated assets of $20 billion or less as of December 31 2017.

Source: OCC

The five federal agencies (Federal Reserve Board, CFTC, Federal Deposit Insurance Corporation (FDIC), OCC, and the Securities and Exchange Commission) have published final amendments to swap margin requirements. The amendments aim to align the definition of “Eligible Master Netting Agreement” in the swap margin rule with the definition of “Qualifying Master Netting Agreement”.

Source: OCC

The five federal agencies have extended the comment period for a proposed change to simplify the ‘Volcker rule’ until 17 October 2018. The Volcker rule restricts banking entities from engaging in proprietary trading and from owning or controlling hedge funds or private equity funds.

Source: SEC

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What have the regulators been up to?

Overseas developments

Industry bodies

PwC publications

Legislative/Government developments

Contacts

4Overseas developments –Asia

HK: Recent news Singapore: Recent news South Korea: Recent news

The Hong Kong Monetary Authority (HKMA) has launched the Faster Payment System (FPS) as part of Smart Banking on 17 September 2018. The system operates on a 24/7 basis and connects banks to Stored-Value Facility (SVF) operators on the same platform. The FPS enables the public to transfer funds across different banks or SVFs with funds available immediately after the transfer. The FPS supports Hong Kong Dollar (HKD) and Renminbi (RMB).

Source: HKMA

The HKMA and the Central Bank of Brazil (BCB) have signed a FinTech Cooperation agreement to help FinTech companies to expand into each other’s markets by collaborating on joint innovation projects, information exchange, mutual consultations and experience sharing.

Source: HKMA

The Monetary Authority of Singapore (MAS) has approved the final features of the new corporate structure for investment funds, the Variable Capital Company (VCC), which includes:

• Establishing as a standalone structure, or as an umbrella structure with multiple sub-funds, thus creating economies of scale as sub-funds can consolidate some administrative functions;

• Using Singapore and international accounting standards in preparing financial statements so that it can cater to the needs of global investors; and

• Providing safeguards against the mixing of assets and liabilities between sub-funds, by requiring segregation of each sub-fund.

Source: MAS

.

The Financial Services Commission (FSC) has proposed an amendment to the Enforcement Decree of the Asset-Backed Securitisation Act by setting rules for determining the monetary penalty to be imposed in case of violations of the Act.

Submissions are due by 22 October 2018.

Source: FSC

The FSC has proposed amendments to the Regulation on Supervision of Electronic Financial Transactions to accelerate the usage of cloud services in the financial sector by:

• Expanding the scope of data managed in the cloud environment; and

• Including standards for secure provision and use of cloud services.

Submissions are due by 30 October 2018.

Source: FSC

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What have the regulators been up to?

Overseas developments

Industry bodies

PwC publications

Legislative/Government developments

Contacts

5 PwC publications

– 15 –

What have the regulators been up to?

Overseas developments

Industry bodies

PwC publications

Legislative/Government developments

Contacts

PwC: Blockchain, a catalyst for new approaches in insurance -Part 2

PwC: Global Insurance Run-off Survey 2018

PwC: InsurTechs are transforming (re)insurers

PwC has released a report, Blockchain, a catalyst for new approaches in insurance: Part 2, synthesising market launches carried out over the 2017-2018 period. The report offers different perspectives that highlight:

• Business cases related to traceability/KYC and the automation of smart contracts;

• Solutions implemented by major market players and newcomers; and

• Initial takeaways, future challenges and approaches to reduce risks related to deploying blockchain technology.

See publication

PwC has released a report on the Global Insurance Run-off Survey 2018. The survey data was sourced from a pool of discontinued non-life insurance businesses.

The report reflected the increasing recognition by owners of discontinued insurance businesses of the benefits associated with pro-active management of legacy liabilities and back books.

See publication

PwC has released a report, InsurTechs are transforming (re)insurers, discussing how various technological innovations are influencing the industry, through:

• Transforming and optimisation of the existing value chain;

• Enabling new capabilities across the value chain;

• Innovating the underwriting of new products and lines; and

• Facilitating partnerships or investments in disruptors outside of the traditional insurance sector.

See publication

5 PwC publications

– 16 –

What have the regulators been up to?

Overseas developments

Industry bodies

PwC publications

Legislative/Government developments

Contacts

PwC US: Digital intelligence -Securing digital bank expansion

PwC US: Digital intelligence -Creating human-centered financial services

PwC US: AML and sanctions -enforcement focus turns to Asia

PwC US has released a report, Digital intelligence - Securing digital bank expansion, outlining the key takeaways on the top digital developments that are influencing financial services. These include:

• The digital entrance gates;

• Digital models raising challenges for authentication and authorisation; and

• Basic security hygiene – embedding security into everything.

See publication

PwC US has released a report, Digital intelligence - Creating human-centred financial services, outlining the specific consumer behaviours that has greater potential for customer-centric services:

• Proxy payment;

• Savings to spend later; and

• Invest in what you know.

See publication

PwC US has released a financial crimes observer, providing key steps that Asian banks should take to comply with growing regulatory scrutiny over their AML and sanctions programs. Key messages from the report are:

• How regulators have shifted their anti-money laundering (AML) sanctions focus from Europe to Asia; and

• Many European banks significantly enhanced their compliance programs after they faced penalties for sanctions and AML-related violations by US regulators, while Asian banks had previously avoided this regulatory scrutiny and as a result, they were not compelled to make the same enhancements.

See publication

6 Contacts

– 17 –

What have the regulators been up to?

Overseas developments

Industry bodies

PwC publications

Legislative/Government developments

Contacts

Nicole SalimbeniPartnernicole.salimbeni@pwc.com(02) 8266 1729

Edwina StarPartneredwina.star@pwc.com(02) 8266 4940

Sarah HofmanPartnersarah.hofman@pwc.com(02) 8266 2231

Craig StaffordPartnercraig.stafford@pwc.com(02) 8266 3725

Amrita JebamoneyPartneramrita.jebamoney@pwc.com(02) 8266 1826

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