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Following a recent announcement of the European Commission’s proposal for a three-month deferral of reporting deadlines under the new DAC6 mandatory disclosure regime in the EU and UK, the Committee of the Permanent Representatives of the Governments of the Member States to the European Union (COREPER) has now reached an agreement on a revised proposal which could possibly defer the reporting deadline for six months. On the basis that the draft Directive, once approved, may be adopted at the discretion of each member state, it is imperative that businesses do not delay in preparing to meet their existing compliance obligations should reporting dates not be deferred (or not be deferred in all Member States where they operate).

The Government of France issued an ordinance (n° 2020-115), which transposes the EU Directive (2018/843) of 30 May 2018 of the European Parliament and of the Council, known as the “5th Anti-Money Laundering Directive”, on 12 February 2020 to aid in the efforts to combat money laundering and the financing of terrorism in France. This ordinance has been supplemented by two decrees (n° 2020-118, n° 1010-119) adopted on the same day.

Covered institutions with a presence in France should carefully analyze the ordinance and its supporting decrees and, where necessary, review and adapt their processes to ensure compliance with the new regulatory framework. In particular, client identity checks need to be adapted.

On 28 April 2020, the Prime Minister gave an outline of the plan to gradually relax the lockdown from 11 May onwards. On 3 May 2020, the Ministry of Labour published a National Deconfinement Plan for companies to ensure the health and safety of employees, link here. Companies which have not already done so must take steps to adapt working conditions to these new recommendations.

The financial markets are experiencing a significant amount of disruption for which there is no precedent. However, in these difficult times it is important that originators, sponsors and securitisation special purpose entities (SSPEs) do not lose sight of their regulatory obligations under Regulation (EU) 2017/2402 (Securitisation Regulation). This short briefing…