Country Manuals Private Banking –
We would like to inform you that BRP has updated its COUNTRY MANUAL PRIVATE BANKING for the following jurisdiction:
BARBADOS OUT OF BANK’S COUNTRY OF ESTABLISHMENT (Def, RS, BT & RT)
Regulatory Template
Material changes
This document has been entirely reviewed in order to reflect an evolution in the interpretation of the legal and regulatory framework. While the legal framework as such has not been significantly amended since the last update, our local experts have suggested to adapt certain approaches on the basis of an evolving interpretation of the regulatory framework.
In addition, we would like to point out the following amendments:
– The financial regulator takes a very strict interpretation of the legislation which prevents any form of solicitation/marketing of the Bank’s financial services, including the Bank’s additional services, offered by a foreign bank in Barbados. The active undertaking of activities related to the offering or provision of debit or credit card services, Lombard credit services or E-banking services to a client in Barbados will therefore be subject to a licensing requirement.
– In general, the Bank’s is not permitted to actively provide generic or personalised recommendation lists into Barbados via remote means of communication unless there is an investment advisory agreement in place which includes these services and which has been signed in compliance with the cross-border rules of Barbados (current interpretation of the regulatory framework).
– (…)
Non-material changes
The document has been reformatted onto the latest template. Many answers in the RT have been re-worded, with an additional reference to applicable law/regulation, to provide more clarity and more detailed explanations.
Regulatory Summary
This document has now a more user-friendly layout and reflects the changes contained in the RT.
Behaviour Template
The answers in the BT have been aligned to those contained in the RT.
BT Short Comparison
BRP has created a comparison document allowing users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “BARBADOS” in the Target Country Field.
The BT Short Comparison should be read as follows:
The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.
Best regards,