24/10/2022

I. Background

Back in March 2015, the CAA issued the Circular Letter 15/01 on notifications in case of cooperation requests by a foreign authority, which invited the professionals subject to its supervision to notify the CAA if they are approached by foreign authorities and requested to provide client information or to cease certain business conduct.

II. Key considerations

The Circular 22/17 repeals and replaces the Circular 15/01 and expands the notification requirements already included in the Circular 15/01.

The Circular 22/17 species that:

  • the CAA should, in addition to the scenarios referred to in the Circular 15/01, also be informed of any reports regarding controls carried out by foreign authorities as well as of any administrative sanctions imposed by these authorities;
  • generally, any information to be provided to the CAA in the scenarios referred to in the Circular 22/17 must be immediately and voluntarily provided, along with all relevant supporting documentation.

 

To read the Circular 22/17 (French only), click here_ 

Please feel free to contact our experts if you need any advice or assistance on the above.

Contacts

Pierre-Michaël de Waersegger

Partner

Banking & Financial Services, Insurance & Reinsurance Law

Emmanuelle Mousel

Partner

Banking & Financial Services, Insurance & Reinsurance Law

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