IBFed Letter to the OECD on Pillar 2 of the new Tax Framework

The International Banking Federation follows up on its previous submissions and comments on Pillar 2, with regard to both the Blueprint document and subsequent statements by the OECD. Further comments are provided on the regulatory capital instruments and adverse outcomes that could arise for Additional Tier 1 (AT1) Capital under the proposed Global anti-Base Erosion (GLoBE) rules in Pillar 2.  IBFed to OECD_Pillar 2_23 Nov 2021

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IBFed comments on European Commission’s Anti Money Laundering consultation and reform package

The International Banking Federation supports the Commission’s view that information sharing is crucial to anti-money laundering and countering terrorist financing (AML/CFT), and that public-private partnerships (PPPs) should be encouraged to the fullest extent possible.  IBFed to EU_AML Reform Package_2 Nov 2021 The International Banking Federation also supports the Commission’s ambition to harmonise national AML/CFT measures through EUlevel legislation, guidance and supervision. Indeed, international regulatory fragmentation has complicated the work of regulators, law enforcement and multinational banking Groups which cannot easily put in place EU-wide AML/CFT programmes. IBFed_Response_to_EU PPPs for AML CFT_2 Nov 2021

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IBFed’s Priorities on Climate Change ahead of the G20 Summit and COP 26

On the 27th of October 2021, IBFed published a letter sharing its views on climate change ahead of the G20 Summit of Heads of State and Government on October 30-31st and the UN Climate Change Conference (COP 26) from October 31-November 12th. We fully support efforts to bring together diverse groups of stakeholders from around the world to discuss actions that should be taken to mitigate and adapt to the effects of climate change. In the letter we elaborate on the following topics: Banks have a key role to play in financing a balanced and orderly transition Global standard setters have an important role in sharing information and harmonizing standards… Read More

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IBFed Letters to the OECD as talks continue at international level to agree on a new tax framework

We acknowledge the significant efforts and investment that member countries, industry and taxpayers have made in contributing to the current Pillar 1 framework. We welcome an approach that is both simple and effective for applying Pillar 1. Banks have a taxable, physical presence in places where they operate regulated business. Therefore, they should be outside the scope of Pillar 1 . Moreover, metrics such as balance sheet or gross revenues do not consider the extremely high capital costs associated with running regulated banks compared with other industries (such as technology and consumer goods companies). We believe that the application of a “worldwide” basis of taxation is a robust equivalent of the Income… Read More

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IBFed memo on Retail Central Bank Digital Currencies and Global Stable Coins

IBFed shares its views on Retail Central Bank Digital Currencies and Global Stable Coins. We assess how the creation of digital currencies could potentially support the digitalization of the economy. We also discuss the role of central banks, commercial banks and other private actors in this journey, the advantages and disadvantages of different scenarios. Last but not least, we address the potential effects to the banking business model and to consumer and commercial customers. To learn more, click here:  CBDC-GSC-memo_18-June-2021 (2)

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IBFed feedback to the IFRS Foundation on the Sustainability Reporting Consultation Paper

The IBFed supports the IFRS Foundation in their efforts to contribute to the development and maintenance of a global set of sustainability reporting standards. The Banking industry strongly supports efforts to establish a generally accepted international framework for sustainability reporting in order to promote consistency and comparability across organizations and reduce the potential for global fragmentation. IBFed Letter to IFRS_24 December 2020

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Comments on the FATF questionnaire on digital transformation

The IBFed’s comments to the Financial Action Task Force (FATF) focus on legal and regulatory barriers to the use of emerging technology for sharing information between regulated banking firms for AML / CFT purposes.  Financial crime information sharing is restricted in many different markets by a misalignment of AML / CFT intelligence needs and data privacy requirements.  We recommend that FATF work with partners to establish international policy roundtables to bring together national, regional and international authorities on AML/CFT and  data protection with the private sector. IBFed to FATF_Digital Transformation_7 Dec 2020

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Response to the OECD Public consultation on Tax challenges arising from Digitisation

The IBFed has responded to the OECD with comments on the design of Pillar II Blueprint. Global banks seek clear and simple rules that are easy to implement and produce a fair outcome for all multinationals. As the proposals in the Pillar II Blueprint are complex, we welcome the proposals to simplify the approach and offer comments as well as suggestions for achieving simplification. IBFed OECD PII submission_14 Dec 2020

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Response to the BCBS on proposed Revisions to the Principles for Operational Risk management

The IBFed has responded to the Basel Committee on Banking Supervision’s proposed revisions to the principles for effective management of operational risk. These revisions have been proposed by the BCBS in the light of banks’ further reliance on outsourced technology and more pervasive cyber threats. The IBFed supports the proposals made, with a few comments on some of the principles.  We welcome the recognition that banks should adopt a proportionate approach to operational risk management, taking into account the nature, size, complexity and risk profile of their activities. IBFed@BCBS_Operational Risk_18 dec 2020  

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