Letter by the European Banking Federation
The European Banking Federation (FBE) welcomes
the launch of an inquiry on the impact of economic and financial
sanctions by the House of Lords Economic Affairs Committee.
The European Banking Federation (FBE) is the
voice of the European banking sector. It represents the interests
of over 4,500 European banks, large and small, from 29 national
Banking Associations, with assets of more than €20,000 billion
and over 2.3 million employees.
We would like to take the opportunity of the
inquiry of the House of Lords Economic Affairs Committee to forward
you our recommendations regarding the functioning of the Consolidated
Electronic List of Persons, Groups and Entities subject to EU
financial sanctions and the drafting, implementation and interpretation
of EU financial sanctions regulations.
The European Banking Federation is first confident
that the Consolidated Electronic List of Persons, Groups and Entities
subject to Financial Sanctions is a major contribution in the
fight against terrorist financing. However, some remaining problems
hinder the use of the list with complete confidence. The remaining
problems are listed in the attached letter[97]
as sent to the European Commission in December 2005.
The FBE has always been willing to co-operate
fully and to ensure a swift and efficient implementation of financial
sanctions. However, our member banks have sometimes encountered
difficulties in the implementation of financial sanctions. Drawing
on its members' experience in implementing sanctions, the FBE
has made some receommendations to the European Commission to improve
the drafting, implementation and interpretation of EU financial
sanctions regulations, especially in light of the Council "Guidelines
on implementation and evaluation of restrictive measures (sanctions)
in the framework of the EU Common Foreign and Security Policy"[98].
97 Letter dated 19 December 2005, from the FBE to
the Directorate General External Regulations, European Commission
(not attached). Back
98
(Council Document 15579/03 of 3 December 2003-hereinafter "the
Council Guidelines") (not attached). Back
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