NFU Consultation Reply to ESMA on Guidelines on Certain Aspects of the MiFID II Compliance Function Requirements (2019)
Summary
These draft guidelines are intended to enhance clarity and foster convergence in implementing certain aspects of the new MiFID II compliance function requirements, replacing the existing ESMA guidelines on the same topic issued in 2012. This Consultation Paper builds on the text of the 2012 guidelines, which have been substantially confirmed (albeit clarified and refined where necessary). In addition, it considers new requirements under MiFID II and the results of supervisory activities conducted by national competent authorities (NCAs) on applying the compliance function requirements.
Nordic Financial Unions (NFU) replied to the consultation, emphasising the view of the Nordic financial sector employees.