Article 78 Communication d’informations aux autorités compétentes

This brief but operationally important article requires obliged entities to maintain systems capable of responding fully and speedily to enquiries from their FIU or other competent authorities.

It connects closely to the broader record-keeping obligations in the regulation, effectively ensuring that the data retained under those obligations can actually be retrieved and communicated when authorities need it.

The focus is on the practical infrastructure side: having the right systems in place to answer questions about whether a business relationship with a specific person exists or has existed.

Important points:

• Implement systems that can respond fully and speedily to authority enquiries about business relationships.
• The lookback window for these enquiries covers a five-year period prior to the enquiry being made.
• All responses must be made through secure channels and in a manner that ensures full confidentiality of the enquiries.