Austrian Financial Market Authority Issues New Other Accounts Due Diligence Ordinance

Key Takeaways

• The Austrian Financial Market Authority has introduced the AndKo-SoV regulation, focusing on due diligence requirements for specific account types.
• This update necessitates a review of existing oversight frameworks to ensure alignment with updated CRD and CRR standards.

Deep Dive

The introduction of the AndKo-SoV ordinance signifies a targeted regulatory focus on the due diligence processes associated with "other accounts" within the Austrian jurisdiction. For compliance teams, this means that existing customer due diligence (CDD) and enhanced due diligence (EDO) protocols must be scrutinized to ensure they meet the specific mandates outlined in this new regulation.

The regulation appears to be closely linked to the Capital Requirements Directive (CRD) and the Capital Requirements Regulation (CRR). This suggests that the scope of the update may extend beyond simple administrative oversight to include implications for capital adequacy and risk management frameworks. Compliance professionals must determine if the ordinance introduces new reporting obligations or changes to the way risk profiles are assessed for these specific account categories.

While the provided update does not specify a granular implementation deadline, the effective date of the document is August 16, 2026. This provides a window for financial institutions to conduct gap analyses and update their internal policies. Compliance officers should prioritize an immediate review of all "other account" workflows to identify potential discrepancies between current practices and the new regulatory expectations.

From a risk perspective, failure to align with the AndKo-SoV could lead to significant regulatory scrutiny or capital penalties under the CRR framework. The impact assessment should focus on operational risk, particularly regarding the accuracy of automated monitoring systems and the adequacy of manual oversight for high-risk account types. Recommended actions include updating the compliance manual, retraining relevant staff, and performing a post-implementation audit once updates are deployed.

Source: Austrian Financial Market Authority