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EBA third-party risk guidelines: two years of transition, and the three changes: third-party arrangements, critical or important functions, ICT services stay with DORA
EBA third-party risk guidelines: what changes for Germany For EBA third-party risk guidelines, the European Banking Authority (EBA) published its final text, EBA/GL/2026/09, on 18 September 2026. It covers any service other than ICT (information and communication technology) services that supports a function on a recurrent or ongoing...

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Million-euro loan reporting Germany: the § 14 KWG reporting ends in December 2026, while large exposure reporting and AnaCredit continue
Million-euro loan reporting Germany ends 30 December 2026 For million-euro loan reporting Germany, the last report covers the reporting date of 30 September 2026. The quarterly notification of loans of EUR 1 million or more under § 14 of the German Banking Act (Kreditwesengesetz, KWG) ends on 30 December 2026, while large...

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Outsourcing vs external procurement: the three boxes for every external service under MaRisk: outsourcing, other external procurement and ICT services under DORA
Outsourcing vs external procurement: MaRisk rules in 2026 For outsourcing vs external procurement, the German Minimum Requirements for Risk Management (MaRisk) ask one question: would the institution otherwise perform the activity itself? Since the ninth MaRisk amendment of 30 June 2026, services covered by the EU Digital Operational...

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PEP checks Germany: what applies to your German branch For PEP checks Germany, your German branch must determine whether a customer or beneficial owner is a politically exposed person (PEP), or a family member or close associate of one, and apply enhanced due diligence if so. The test comes from German law and a European Commission...

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High-risk third countries list: what applies in Germany The EU high-risk third countries list currently names 26 jurisdictions, and your German branch must apply enhanced due diligence whenever one of them is involved. The list comes from the European Commission and differs from the lists of the Financial Action Task Force (FATF). ...

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