Intent Declared Summary

The International Monetary Fund's (IMF) 2006 detailed assessment, in which insurance supervisory practices in Spain were benchmarked against the Insurance Core Principles (ICPs) promulgated by the International Association of Insurance Supervisors in 2003, concludes that Spain fully observes 17 of the 28 ICPs, largely observes 6 ICPs, and partly observes 5 ICPs. While insurance supervision and regulation rely on a clear legal framework, the regulatory framework does not provide specific requirements on risk assessment and management. Weaknesses were also identified in terms of independence and governance of the supervisory authority--the Directorate General of Insurance and Pension Funds (DGSFP)--specifically its reliance on the Ministry of Economy and Finance (MEH) to issue legally binding secondary regulation. In addition, Spain lacks requirements on corporate governance for insurers, regular analysis of market conditions, and group-wide supervision of financial conglomerates in the insurance sector. Responding to the IMF assessment, the DGSFP noted that legislative amendments were expected to be adopted to bring Spanish regulations in line with the IMF recommendations, notably in the areas of licensing, suitability of persons, corporate governance, internal control, investments, financial derivatives and Anti-Money Laundering and Combating the Financing of Terrorism. As observed by the IMF's 2007 and 2008 Article IV reports, recommendations to separate insurance supervisory functions from the MEH have been put on hold and a proposal to launch a “twin peaks” model with solvency regulation under the Bank of Spain and consumer protection under the National Securities Market Commission is also stalled.

General Overview

The Directorate General of Insurance and Pension Funds (DGSFP)--an entity within the Ministry of Economy and Finance (MEH)--is the regulatory and supervisory authority for the insurance and pension fund sector in Spain. The DGSFP is vested with licensing powers, and is a member of the International Association of Insurance Supervisors (IAIS). Spain is divided into 17 regions, also known as autonomous communities (CAs), with each CA operating under its own legal framework. A International Monetary Fund's (IMF) 2006 detailed assessment of Spain's observance of the Insurance Core Principles (ICPs) states that while the CAs have legal powers to license and supervise insurance companies and intermediaries--mainly small social mutual societies--only a few exercise this legal capacity.

Insurance regulation and supervision in Spain relies on a clear legal framework, according to the IMF's 2006 report. General laws include the Law on Private Insurance Organization and Supervision No. 30 of 1995, the Law on Private Insurance and Reinsurance Intermediation No. 26 of 2006, and European Union (EU) Directives. According to the IMF's 2006 assessment, secondary regulation is issued through Royal Decrees and Ministerial Ordinances. As the DGSFP is not an independent agency, it relies on the MEH to issue secondary regulation that is legally binding, such as Circulars. The European Commission website discloses that the Commission adopted the Solvency II Proposal in July 2007. The EU’s Solvency II framework, which aims to introduce a more risk-oriented approach to solvency supervision in the insurance sector on an EU-wide basis, is based on a three pillar approach that covers quantitative and qualitative solvency requirements, as well as supervisory reporting and disclosure. The framework emphasizes risk management and stress testing, in which Spain maintains a leadership position, according to the IMF's 2006 report.

According to the IMF's 2006 assessment, in which insurance supervisory practices were benchmarked against ICPs and Methodology revised by the IAIS in October 2003, Spain fully observes 17 of the 28 ICPs, largely observes 6, and partly observes 5. While insurance supervision and regulation relies on a clear legal framework, there are no specific requirements on risk assessment and management, the IMF notes. Weaknesses were also identified in terms of independence and governance of the supervisory authority, specifically its reliance on the MEH to issue secondary regulation that is legally binding. Furthermore, Spain lacks requirements on corporate governance for insurance companies, regular analysis of market conditions, and group-wide supervision of financial conglomerates in the insurance sector. Responding to the IMF assessment, the DGSFP noted that new regulatory initiatives were expected to bring Spanish regulations in line with the IMF recommendations, notably in the areas of licensing, suitability of persons, corporate governance, internal control, investments, financial derivatives and Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT). As reported in the IMF's 2007 and 2008 Article IV reports, recommendations to separate insurance supervisory functions from the MEH have been put on hold and a proposal to launch a “twin peaks” model with solvency regulation under the Bank of Spain (BdE) and consumer protection under the National Securities Market Commission (CNMV) is also stalled.

The Spanish insurance market ranks ninth among the Organisation for Economic Cooperation and Development (OECD) economies, cites the OECD.Stat Extract website, with a market share of 1.93 percent and net premium income amounting to USD 91.3 billion in 2008. Insurance penetration stood at 5.44 percent and insurance density was USD 1,663 in the same year. The insurance market is dominated by the nonlife sector (accounting for 55.6 percent of the market in 2008). There were a total of 293 domestic insurance undertakings and 31 foreign companies operating in Spain in 2008. Despite the smaller numbers, as the U.S. Department of Commerce (DoC) states in its 2010 Country Commercial Guide, nearly one third of the insurance market in Spain is controlled by foreign firms. The U.S. DoC report also notes that these foreign investors have achieved "profitable results and excellent market positions."

The Principles

FCICP 1 Conditions for effective insurance supervision

This principle is observed, according to the IMF's 2006 detailed assessment. Pursuant to the Financial Services Action Plan, the regulatory and supervisory framework is comprehensive, specifically in the insurance sector. The IMF report further notes that "institutional arrangements for financial supervision, including laws and regulations, are clearly defined and publicly disclosed" (p. 10). Spain has established a well-developed accounting and auditing framework for insurance activities, which is generally in line with international best practices. Per the same report, the judicial system is professional and reliable, with private arbitration mechanisms. The supervisory scheme is also supported in an efficient manner by the market infrastructure. The IMF finally reports that efficient and competitive financial markets in Spain enable insurers "to have access to a wide range of financial instruments to properly comply as institutional investors and to manage their risks in an appropriate manner" (p. 10).

FCICP 2 Supervisory objectives

According to the IMF's 2006 detailed assessment, Spain observes this principle. Supervisory objectives and the role of the insurance supervisory authority are clearly defined in the Law on Private Insurance Organization and Supervision No. 30 of 1995. The IMF report notes that objectives of the supervisory scheme include "pursuing the sound and transparent development of the insurance industry and the protection of policyholders and beneficiaries" (p. 10).

NCICP 3 Supervisory authority

This principle is only partly observed, according to the IMF's 2006 detailed assessment. As stated on the MEH website, the DGSFP--an entity within the MEH--is the regulatory and supervisory authority for the insurance and pension fund sectors in Spain. The DGSFP is also vested with licensing powers, and is a member of the IAIS. Spain is divided into 17 regions, also known as CAs, with each CA operating under its own legal framework. The IMF's 2006 report states that while the CAs have legal powers to license and supervise insurance companies and intermediaries, only few exercise this legal capacity. According to the IMF report, Spain "is not compliant with ICP 3 in terms of independence and governance of the supervisory body" (p. 12). As the DGSFP is not an independent agency, it relies on the MEH to issue secondary regulation that is legally binding, such as Circulars. The IMF report also notes that Spain lacks "explicit procedures regarding the appointment and dismissal of the head of the insurance supervisory authority" (p. 12). It is further highlighted that the DGSFP has limited resources "to attract and retain highly skilled personnel and to develop all the necessary supervisory infrastructure and tools" (p. 12). In this context, it is recommended by the IMF that the DGSFP be given full operational and budgetary independence, as well as legal powers to issue secondary regulation that is binding to the insurance industry. As reported in the IMF's 2007 and 2009 reports, recommendations to separate insurance supervisory functions from the MEH have been put on hold and a proposal to launch a “twin peaks” model with solvency regulation under the Bank of Spain (BdE) and consumer protection under the National Securities Market Commission (CNMV) is also stalled.

FCICP 4 Supervisory process

Spain observes this principle, as stated in the IMF's 2006 detailed assessment. As stated in the IMF report, pursuant to the Law on Private Insurance Organization and Supervision, "the DGSFP has clear and comprehensive supervisory procedures in place for insurance supervision" (p. 12). The supervisory process is risk-oriented, and takes place in a consistent and equitable manner. Moreover, necessary measures are implemented in a timely fashion. Decisions adopted by the DGSFP can be appealed before the MEH or the judicial system by insurers. Information on recent developments and conditions of the market is also made available through the DGSFP's annual report and website.

FCICP 5 Supervisory cooperation and information sharing

According to the IMF's 2006 detailed assessment, Spain observes this principle. The IMF report notes that the Law on Private Insurance Organization and Supervision establishes "the general legal framework for the collaboration and exchange of information with other financial supervisors" (p. 13). The DGSFP has concluded bilateral memoranda of understanding for collaboration and exchange of information with the BdE and the CNMV. Legislation also establishes the conditions for collaboration and exchange of information with EU and non-EU supervisors. As stated in the IMF's 2006 detailed assessment of Spain's compliance with the Basel Core Principles for Effective Banking Supervision, the Law on Reform Measures of the Financial System No. 44 of 2002 provides for "cooperation between banking, securities, and insurance supervisors, aimed at harmonizing supervisory criteria, practices, and techniques and sharing the information these supervisors require to carry out their duties" (p. 15). It is recommended that cooperation between the MEH and the banks, securities, and insurance supervisors with respect to the regulation of financial products be enhanced. In this respect, the 2009 IMF report remarks that an institutional mechanism for permanent and continued coordination among the main financial regulators was created with the establishment of the Financial Stability Committee.

CPICP 6 Licensing

This principle is only largely observed, according to the IMF's 2006 detailed assessment, as the regulatory framework does not include specific requirements for actuaries participating in the technical management of insurers during the licensing process. The IMF report states that legislation clearly defines insurance activity, and establishes the responsibility for the licensing process. Fit and proper testing is required to conduct insurance activity, and applies to owners, Board members, senior management and auditors. Regarding the licensing process for foreign entities, prior confirmation is needed from the home supervisory authority to ensure that the insurer complies with all the regulatory requirements in the home jurisdiction. The IMF report recommends establishing "specific suitability requirements for the actuaries that will participate in the technical management of the company" (p. 28), as part of the licensing process for insurance companies. Responding to the IMF assessment, the DGSFP notes that Spanish Law requires insurance companies to have an insurance actuary at their disposal. There are no further updates with regards to this principle, as of July 2010.

CPICP 7 Suitability of persons

This principle is only largely observed, according to the IMF's 2006 detailed assessment, as fit and proper testing does not apply to actuaries participating in the technical management of insurers. Moreover, insurers are not required by law to notify the supervisory authority of breaches to the fitness and propriety of its personnel. The IMF report notes that the Law on Private Insurance Organization and Supervision establishes "the general fit and proper requirements that owners should meet and key personnel of an insurer" (p. 14). The DGSFP has the authority to withdraw the license of owners and key personnel whenever these requirements are no longer met. The assessment of the suitability of auditors relies on the Institute of Accounting and Auditing (ICAC). Actuaries should be required to comply with specific fit and proper standards. It is further advised by the IMF "to introduce the obligation for insurers to inform the supervisory authority, in a timely manner, of circumstances that may affect the fitness and propriety of its key functionaries (p. 28). Responding to the IMF assessment, the DGSFP notes that a legislative amendment is expected to be adopted to include the requirement of propriety for insurance actuaries. There are no further updates with regards to this principle, as of July 2010.

FCICP 8 Changes in control and portfolio transfers

This principle is observed, according to the IMF's 2006 detailed assessment. The IMF report notes that the DGSFP should be informed of any significant participation. Within a period of three months, the DGSFP has the authority to deny authorization for acquisition or change in control. Portfolio transfers, on the other hand, require the prior approval of the MEH.

NCICP 9 Corporate governance

This principle is only partly observed, according to the IMF's 2006 detailed assessment, "as neither general law nor Insurance Law establishes requirements on corporate governance for insurance companies" (p. 16). Moreover, legislation in place only applies to a limited number of listed insurance companies. The regulatory framework for corporate governance was then mainly comprised of the 2003 Order on the Annual Report of the Corporate Governance and Other Reporting Instruments of the Public Joint Stock Companies and Other Entities No. ECO/3722/2003, and the CNMV Circular on the Annual Corporate Governance Report No. 1 of 2004. This latter, however, was only applicable to listed insurance companies, which numbered two at the time of the IMF assessment. In this context, the IMF report recommended establishing "general requirements on corporate governance applicable to insurers in which clear responsibilities for the board of directors and senior management are included" (p. 29). The Unified Code on Good Corporate Governance and its recommendations went into effect in 2007. According to a 2009 article by Fernando Vives, the Unified Code is “one of the most noteworthy recent milestones in the area of corporate governance in Spain” (p. 170) and its recommendations have raised the bar for companies’ required practices. Further, “Spanish companies have been diligently applying (these standards) in recent years” (Vives, p. 170). Notable features of the Unified Code include stipulations on the size and structure of board of directors, the formation of nomination and remuneration committees, and the independence of directors. The 2010 U.S. DoC CCG, however, points out that “due to extensive cross-ownership within a small universe of dominant companies, Spanish corporations have traditionally not had truly independent board members” (p. 101). Fernando Vives in his 2009 report recommends improvements in independence of directors, compensation policy, and disclosure for boards. Nevertheless, there is insufficient information whether insurance companies are subject to the requirements of the Unified Code.

CPICP 10 Internal control

This principle is largely observed, according to the IMF's 2006 detailed assessment. Under the current regulatory framework, the IMF notes that insurance companies are not explicitly required "to have an internal control framework that includes internal auditing, risk management systems, assessment of outsourced functions and a clear responsibility of the board of directors" (p. 16). Responding to the IMF assessment, the DGSFP notes that it is considering a draft amendment to the Law on Private Insurance Organization and Supervision No. 30 of 1995 "that provides for the establishment, documentation, and maintenance, at all times, of internal control procedures adapted to the company's organization" (p. 31). The law underwent several amendments since then and was last amended in 2009; however, there is insufficient information as to whether the amendments incorporate the IMF recommendations and DGSFP intent.

NCICP 11 Market analysis

Spain partly observes this principle, as stated in the IMF's 2006 detailed assessment. While the DGSFP produces publicly available aggregated market data, market conditions are only analyzed on an ad hoc basis. Moreover, insurance companies are not required "to engage in market-wide systematic reporting, or to analyze and monitor particular market-wide events of importance for the financial stability of insurance markets" (p. 17) according to the IMF report. In this context, the IMF recommends conducting regular analysis of market conditions. Insurers should also provide information that is necessary for the regular analysis of market conditions. As of July 2010, there are no updates as to whether this advice was acted upon.

FCICP 12 Reporting to supervisors and off-site monitoring

This principle is observed, as stated in the IMF's 2006 detailed assessment. Financial institutions in Spain are subject to BdE rules, which, per a 2010 Pricewaterhouse Coopers (PwC) report, comply with EU-endorsed International Financial Reporting Standards (IFRSs). According to the regulatory and standard-setting framework assessment published by the Institute of Auditors of Spain in June 2005, the DGSFP takes part in the accounting and auditing standard-setting process through a representative in the Audit and Accounting Committees of the Institute of Accounting and Auditing. The DGSFP further carries out inspections of insurance companies to verify compliance with accounting and auditing requirements.

FCICP 13 On-site inspection

This principle is observed, as stated in the IMF's 2006 detailed assessment. Pursuant to the Law on Private Insurance Organization and Supervision, the IMF notes that "the DGSFP has wide-ranging powers to conduct on-site inspections and gather information" (p. 18). The IMF report further notes that the DGSFP has established "clear and comprehensive procedures to conduct on-site examinations" (p. 18).

FCICP 14 Preventive and corrective measures

This principle is observed, according to the IMF's 2006 detailed assessment. Pursuant to the Law on Private Insurance Organization and Supervision, the DGSFP has powers to implement different preventive and corrective measures. The Law further includes special control measures, which enable the DGSFP "to require a plan for correction of problems detected in off-site analysis or in on-site inspections" (p. 18), the IMF report observes.

FCICP 15 Enforcement or sanctions

Spain observes this principle, as noted in the IMF's 2006 detailed assessment. Pursuant to the Law on Private Insurance Organization and Supervision, the DGSFP has adequate power to properly enforce corrective actions. According to the IMF report, the Law provides an administrative sanctions scheme, and clearly defines "the legal power to impose sanctions based on clear criteria that are publicly disclosed" (p. 19).

FCICP 16 Winding-up & exit from the market

Spain observes this principle, according to the IMF's 2006 detailed assessment. According to the IMF report, the Law on Private Insurance Organization and Supervision clearly defines "the situations in which an insurer should exit the market and the procedures for winding-up are clearly defined in the regulation" (p. 19). The IMF report also notes that from the government's perspective, the Insurance Compensation Consortium (CCS) also constitutes an important part of the winding-up mechanism, as it performs the administrative liquidation of insurance entities.

NCICP 17 Group-wide supervision

Spain partly observes this principle, as stated in the IMF's 2006 detailed assessment. Supervision of financial conglomerates is defined under the Law on Supervision of Financial Conglomerates No. 5 of 2005. The IMF report notes that while the DGSFP has signed memoranda of understanding with the BdE and the CNMV, coordination and collaboration on supervision of financial conglomerates is limited to exchange of information on an ad hoc basis. Furthermore, there is a lack of group-wide supervision of financial conglomerates in the insurance sector. In this regard, the IMF report recommends increasing cooperation between the DGSFP, the BdE and the CNMV "in order to create and implement effective mechanisms for group-wide analysis and effective group-wide supervision of financial conglomerates" (p. 29). It is also recommended that the DGSFP be provided with necessary resources to effectively take part in group-wide supervision. There are no updates, as of July 2010, if these recommendations have been acted upon.

NCICP 18 Risk assessment and management

Spain partly observes this principle, as stated in the IMF's 2006 detailed assessment. Pursuant to the Law on Private Insurance Organization and Supervision, insurance companies are required to establish general internal control procedures, as part of the licensing process. The IMF report concludes, however, that the regulatory framework lacks "specific requirements on risk assessment and management for insurers to recognize the wide range of risks that they face and to assess and manage them in an appropriate manner" (p. 20). As part of the supervisory process, the IMF report recommends conducting a "regular assessment of the aggregation and correlation of risks, risk diversification, and the overall effect that specific financial and technical risks might have on the global position of supervised insurers" (p. 29). There are no updates, as of July 2010, if these recommendations have been acted upon.

FCICP 19 Insurance activity

This principle is observed, according to the IMF's 2006 detailed assessment. Pursuant to the Law on Private Insurance Organization and Supervision, insurance companies are required to establish specific underwriting and pricing policies. The IMF report states that the DGSFP "checks regularly that insurance companies evaluate the risks that they underwrite, and establish and maintain an adequate level of premiums" (p. 21). Moreover, reinsurance arrangements are regularly reviewed by the DGSFP "to check that they are adequate and that the claims held by insurers on their reinsurers are recoverable and properly accounted" (p. 21).

FCICP 20 Liabilities

Spain observes this principle, according to the IMF's 2006 detailed assessment. The IMF report notes that the regulatory framework clearly sets out "the necessary elements for establishing adequate technical provisions and for the assessment of their adequacy" (p. 21). Furthermore, the DGSFP regularly assesses the adequacy of technical provisions through offsite and on-site examinations.

CPICP 21 Investments

This principle is only largely observed, according to the IMF's 2006 detailed assessment, as the regulatory framework does not require insurance companies to establish "an overall strategic investment policy approved and reviewed regularly by the Board of Directors" (p. 22). Furthermore, regulation lacks specific fit and proper requirements for staff taking part in investment activities. The IMF observes that the regulatory framework should also provide for audit procedures "to ensure the timely identification of internal control weaknesses and operating system deficiencies on investment operations that include contingency plans" (p. 29). Responding to the IMF assessment, the DGSFP notes that it is considering a draft amendment to the Law on Private Insurance Organization and Supervision No. 30 of 1995 to clearly establish that "responsibility for formulating and approving the investment policy rests with the insurance company's board of directors, which must ensure the identification, follow-up, measurement, reporting, and management of risk" (p. 32). The law underwent several amendments since then and was last amended in 2009; however, there is insufficient information as to whether the amendments incorporate the IMF recommendations and DGSFP intent.

CPICP 22 Derivatives and similar commitments

This principle is only largely observed, according to the IMF's 2006 detailed assessment, due to the lack of risk management systems and audit procedures covering the risks from derivative products. Furthermore, the IMF report observes, the regulatory framework does not explicitly require that the board of directors "satisfy itself that it has the necessary expertise to understand the important issues related to the use of derivatives" (p. 23). The board of directors should approve and regularly review its policy on the use of derivative products. Responding to the IMF assessment, the DGSFP underlines the necessity to establish "clear, written rules on the usable categories, purpose, maximum positions, and authorized counterparties" (p. 32). In addition, these rules should provide for "a sharing of the authorization, execution, and control functions, and for periodic documentation of all activities" (p. 32). However, as of July 2010, there are no updates on the follow-up on these fronts.

FCICP 23 Capital adequacy and solvency

Spain observes this principle, according to the IMF's 2006 detailed assessment. The IMF report notes that the regulatory framework adequately addresses issues related to capital adequacy and solvency, as well as valuation of technical provisions. The European Commission website disclosed that the Commission had adopted the Solvency II Proposal in July 2007. The EU’s Solvency II framework, which aims to introduce a more risk-oriented approach to solvency supervision in the insurance sector on a EU-wide basis, is based on a three pillar approach that covers quantitative and qualitative solvency requirements, as well as supervisory reporting and disclosure.

FCICP 24 Intermediaries

This principle is observed, according to the IMF's 2006 detailed assessment. The Law on Private Insurance and Reinsurance Intermediation No. 26 of 2006--which replaces the Law on Private Insurance Intermediation No. 9 of 1992--was enacted in 2006 to incorporate the EU Directive on Insurance Mediation No. 2002/92/EC. The IMF report notes that insurance intermediaries, including insurance agents and brokers, are required to be licensed under the Law on Private Insurance and Reinsurance Intermediation.

FCICP 25 Consumer protection

This principle is observed, according to the IMF's 2006 detailed assessment. The IMF report states that both the Law on Private Insurance Organization and Supervision and the Law on Private Insurance and Reinsurance Intermediation "establish requirements to both insurers and intermediaries, to act with due skill, care, and diligence in their dealing with their consumers" (p. 24).

FCICP 26 Information, disclosure & transparency towards the market

This principle is observed, according to the IMF's 2006 detailed assessment. The IMF report notes that the DGSFP "monitors the information disclosed by insurers and is able to take the necessary actions to ensure compliance with legal disclosure requirements" (p. 25). Pursuant to the Law on Private Insurance Organization and Supervision, insurance companies and insurance groups are required to make publicly available their audited financial statements, as well as annual report, management report, and audit report on an annual basis.

FCICP 27 Fraud

Spain observes this principle, according to the IMF's 2006 detailed assessment. Insurance fraud is criminalized under the Organic Law on Penal Code No.10 of 1995. As part of the on-site inspection process, the IMF notes, the DGSFP "reviews the internal control systems in place by the insurers to detect, and prevent fraudulent activities" (p. 25). The IMF report further notes that while insurance companies are not required by law to take specific measures to prevent fraud, the insurance industry has taken steps in this direction.

CPICP 28 Anti-money laundering/ Combating the Financing of Terrorism

This principle is only largely observed, as stated in the IMF's 2006 detailed assessment, as the AML/CFT framework did not apply to insurance intermediaries. It was recommended by the IMF that the DGSFP be provided with the necessary resources to effectively examine compliance with AML/CFT requirements of insurers. The IMF report further encouraged drafting legislation on AML/CFT requirements for insurance intermediaries. Responding to the IMF assessment, the DGSFP noted that a legislative amendment was expected to be adopted "to maintain the aforesaid accountability of the companies for the actions of their agents" (p. 32). In addition, the legislative amendment would provide that "insurance brokers remain directly bound by legal obligations with regard to specific measures to prevent money laundering, irrespective of the insurance companies for which they carry out trading activities" (IMF 2006, p. 32). With regard to the passage of a new AML/CFT Law, the U.S. Department of State's 2010 report mentions that in April 2010, Law No. 19 of 1993 was unified with Law No. 12 of 2003 on the Prevention and Blocking of the Financing of Terrorism and Royal Decree 925 of 1995 to form the new Law No. 10 for the Prevention of Money Laundering and Financing of Terrorism. This was in response to a formal complaint lodged by the European Commission against Spain for “inadequate implementation of EU norms against money laundering,” (p. 195) according to the 2010 U.S. DoS report. Per the same agency’s 2008 report, the Financial Action Task Force's mutual evaluation report, which was released in June 2006, identified shortcomings in the areas of customer due diligence and beneficial ownership of legal persons, which still need to be worked on per the 2010 report. The report expects the new AML/CFT Law (No. 10) to improve the authorities’ capacity to fight terrorism financing. Nonetheless, Spain is still advised to increase the resources and independence of the Executive Service of the Commission for Monitoring Exchange Control Offences (SEPBLAC), the country’s financial intelligence unit, as well as other regulators to enable more effective discharge of their AML/CFT-related functions.