EFAMA welcomes this opportunity to comment on the review of the provisions within the Short Selling Regulation. We have limited our responses to those questions of most relevance to our membership.
Policy
ESMA Consultation on the review of certain aspects of the short selling regulation
EFAMA’s Views on the Anti-Money Laundering Package
As the European Union’s financial system has become more complex, it has also opened the door to new risks of money laundering and terrorist financing. EFAMA supports the new regulatory package proposed by the Commission on 20 July 2021, believing this initiative will make strides in ensuring that no loopholes or weak links in the internal market allow criminals to use the EU to launder the proceeds of their illicit activities.
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EC Public Consultation on draft Guidelines on the role, tasks and responsibilities AML/CFT compliance officers
EFAMA shared its views on the EBA’s Draft Guidelines on policies and procedures in relation to compliance management and the role and responsibilities of the AML/CFT Compliance Officer under Article 8 and Chapter VI of Directive (EU) 2015/849 (the ‘Draft Guidelines’).
EFAMA's response to the EBA consultation on draft RTS criteria for the identification of shadow banking entities
Ever since the term “shadow banking” has emerged from the FSB’s working circles in the immediate aftermath of the 2008 global financial crisis[1], our association has consistently argued that its use as a reference to regulated asset management companies and their funds is inaccurate and mis-leading.