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[18859]
May 17, 2005
TO: INTERNATIONAL MEMBERS No. 13-05
INTERNATIONAL OPERATIONS ADVISORY COMMITTEE No. 9-05
MONEY LAUNDERING RULES WORKING GROUP No. 5-05
TRANSFER AGENT ADVISORY COMMITTEE No. 22-05
RE: INSTITUTE COMMENT LETTER ON IOSCO’S AML CONSULTATION PAPER
Attached is a comment letter to the International Organization of Securities
Commissions (IOSCO) in response to its consultation report on anti-money laundering
responsibilities for collective investment schemes (CIS), such as mutual funds. The consultation
report was issued earlier this year.1
In general, the letter supports the report and commends IOSCO’s Technical Committee
on their work in this area. Despite that general support, however, the draft letter expresses
concerns over three aspects of the report:
• First, that the report overstates, in certain respects, the responsibility of CIS to verify
the identity of beneficial owners of accounts held by intermediaries;
• Second, that the report may inappropriately suggest that CIS should be treated like
securities firms with respect to the types of information they are expected to collect
from investors; and
1 See Memorandum No. 18635, dated March 8, 2005.
2
• Third, that the report is overly prescriptive in the section dealing with the
performance of AML responsibilities by other financial institutions or service
providers.
Robert C. Grohowski
Associate Counsel
Attachment (in .pdf format)
Note: Not all recipients receive the attachment. To obtain a copy of the attachment, please visit our members
website (http://members.ici.org) and search for memo
18859, or call the ICI Library at (202) 326-8304 and request the attachment for memo 18859.