The trade association for asset managers DUFAS has responded to the consultation on the second tranche of the International Sanctions Measures Bill (WIS). DUFAS supports the importance of an effective and proportionate sanctions framework, but simultaneously calls for attention to proper alignment with existing European regulation.

Specifically, DUFAS highlights the need for greater clarity on the relationship between the WIS and European anti-money laundering regulation (AMLR and AMLD). It is essential for institutions to have a clear picture of which obligations flow directly from European regulation and where the WIS adds to those, in order to avoid overlap, ambiguity and unnecessary administrative burdens.

In addition, DUFAS advocates a national risk assessment (NRA) that is sufficiently sector-specific. Examples, case studies and typologies must be genuinely relevant and usable for the asset management sector, with the NRA focusing primarily on inherent risks rather than on existing control measures already in place at institutions.

Source:  dufas.nl/actueel/dufas-reageert-op-consultatie-internationale-sanctiemaatregelen/