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Version date: 31 July 2020 - onwards

6. Adequate knowledge, skills and experience

Closed
31 October 2020

57. Members of the management body should have an up-to-date understanding of the business of the institution and its risks, at a level commensurate with their responsibilities. This includes an appropriate understanding of those areas for which an individual member is not directly responsible but is collectively accountable together with the other members of the management body.

58. Members of the management body should have a clear understanding of the institution's governance arrangements, their respective role and responsibilities and, where applicable, the group structure and any possible conflicts of interest that may arise therefrom. Members of the management body should be able to contribute to the implementation of an appropriate culture, corporate values and behaviour within the management body and the institution [See also the EBA's Guidelines on Internal Governance]. Members of the management body that are responsible for the implementation of the laws, regulations and administrative provisions necessary to comply with Directive (EU) 2015/849 should have adequate knowledge, skills and experience regarding ML/TF risk identification and assessment, and AML/CFT policies, controls and procedures. They should have a good understanding of the institution and its business model, and the extent to which this exposes the institution to ML/TF risks.

59. In this respect, the assessment of adequate knowledge, skills and experience should consider:

a. the role and duties of the position and the required capabilities;