Pending Comment Letters

Your comments are extremely important to us to provide the best response by WOCCU to these regulatory proposals.

Listed below are all pending regulatory actions for which WOCCU intends to submit a Comment Letter. The listed date is the date by which Comments are due to the respective agency. All Comment Letters filed by WOCCU can be viewed on the Comments & Position Papers tab. Comments filed by the European Network of Credit Unions can be found here.

Please be sure to provide us with your comments in advance of the Due Date so that we may include them in our Comment Letter.

Agency	Pending Comment Letters	Due Date
FATF	Risk-Based Guidance on Recommendation 25 (Beneficial Ownership and Transparency of Legal Arrangements)	December 8, 2023
Committee on Payments and Market Infrastructures (Bank for Int'l Settlements)	Linking Fast Payment Systems Across Borders: Considerations for Governance and Oversight	December 13, 2023
European Commission	Critical ICT Third-Party Service Providers - Criteria & Fees	December 14, 2023
Basel Committee	Disclosure of Banks' Cryptoasset Exposures	January 31, 2024
Basel Committee	Discussion Paper on Digital Fraud	February 16, 2024
Basel Committee	Disclosure Framework for Climate-Related Financial Risk	February 29, 2024

Recent News on our Competent Authorities

2023-08-22

FATF Issues Targeted Update on Implementation of FATF Standards on Virtual Assets

The Financial Action Task Force has issued its Targeted Update on the Implementation of FATF Standards on Virtual assets calling for all countries to rapidly implement measures on virtual assets (VA) and virtual asset service providers (VASPs).

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FATF

FATF Issues Targeted Update on Implementation of FATF Standards on Virtual Assets

2023-04-11

FATF Finalizes Guidance On Beneficial Ownership of Legal Persons

The Financial Action Task Force finalized its guidance to provide tougher global beneficial ownership standards in its Recommendation 24 by requiring countries to ensure that competent authorities have access to adequate, accurate and up-to-date information on the true owners of companies. This guidance will help implement the revised Recommendation 24. If implemented properly by national-level authorities, it will provide efficient and rapid access to the information for use by financial institutions including credit unions to help with their AML/CFT responsibilities with respect to legal entities.

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FATF

FATF Finalizes Guidance On Beneficial Ownership of Legal Persons

2022-03-16

WOCCU Applauds FATF Strengthening of Beneficial Ownership Standards

The Financial Action Task Force made amendments to FATF Recommendation 24 and its Interpretive Note to strengthen the international standards on beneficial ownership of legal persons to ensure greater transparency about the ultimate ownership and control of legal persons. This not only will mitigate the risks of their misuse, but will require Countries to have a public authority or body function as a beneficial ownership registry (or alternative mechanism) that can provide efficient access to adequate, accurate and up-to-date beneficial ownership information by competent authorities.

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FATF

WOCCU Applauds FATF Strengthening of Beneficial Ownership Standards

2022-01-21

International Advocacy at World Council Releases 2022 Global Regulatory Update

This week the International Advocacy team at the World Council of Credit Unions (World Council) released the 2022 Global Regulatory Update. The update highlighted the leading regulatory issues currently affecting credit unions including sustainable finance, proportionality, financial inclusion, anti-money laundering and countering the financing of terrorism (AML/CFT), payments and digitization. With sustainable finance as the feature of the report, it was noted that we should look forward to regulations that will encourage investments in environmentally responsible products as well as related regulations that govern procedure, including disclosures and reporting requirements.

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FATF, G20

International Advocacy at World Council Releases 2022 Global Regulatory Update

2021-11-01

FATF Acknowledges Burden of AML/CFT Requirements on the Advancement of Financial Inclusion

The Financial Action Task Force released their, “Cross-Border Payments Survey Results on Implementation of the FATF Standards”, in response to survey created to identify conflicts between AML/CFT rules and implementation, and cross-border payments. According to FATF, “The survey results highlight, among others, that lack of risk-based approach and inconsistent implementation of the AML/CFT requirements increases cost, reduces speed, limits access and reduces transparency.”

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FATF

FATF Acknowledges Burden of AML/CFT Requirements on the Advancement of Financial Inclusion

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