Horizontal control analysis examining a sample of summary tables of the overall assessment of the risks of money laundering and/or terrorist financing

NBB_2020_002 – 23 January 2020 Communication – Page 1/8 Boulevard de Berlaimont 14 – BE-1000 Brussels Phone +32 2 221 24 33 Company number: 0203.201.340 RPM (Trade Register) Brussels www.nbb.be Communication Brussels, 23 January 2020 Reference: NBB_2020_002 Contact person:
Justien Boussauw tel. +32 2 221 38 33 justien.boussauw@nbb.be Horizontal control analysis examining a sample of summary tables of the overall assessment of the risks of money laundering and/or terrorist financing Scope All companies subject to the supervision of the National Bank of Belgium that fall within the scope of the Law of 18 September 2017 on the prevention of money laundering and terrorist financing and on the restriction of the use of cash, including:

• all credit institutions, including EU and non-EU branches;
• all stockbroking firms, including EU and non-EU branches;
• all insurance companies authorised to conduct life insurance business, including EU and
  non-EU branches;
• all payment institutions and electronic money institutions governed by Belgian law,
  including branches established in Belgium of EU and non-EU institutions, and payment institutions and electronic money institutions authorised in another country of the European Economic Area which are required to designate a central contact point in Belgium;
• all settlement institutions falling within the scope of the Law of 18 September 2017.
  Summary/Objectives
  Through this communication, the National Bank of Belgium aims to draw lessons from the summaries of the first “overall risk assessments” performed by the financial institutions in accordance with Article 16 of the Law of 18 September 2017 on the prevention of money laundering and terrorist financing and on the restriction of the use of cash, and to communicate these to the financial institutions in order to improve the quality and relevance of these assessments. Structure
  I. General comments
  II. The distinction between the ORA and the reporting of results to the Bank
  III. The ORA process
  IV. Identification of risks (phase 1)
  V. Gap analysis (phase 2)
  VI. Importance of an ambitious action plan (phase 3)