Country Manual Private Banking
Israel Permit all – Update 2024
BRP has updated its Country Manual Private Banking for Israel permit all out of Bank’s Country of Establishment (DEF, RS, BT & RT)
| Source of changes | Answers |
|---|---|
| Law / Regulation | No |
| New Position of the Authorities | Yes |
| Evolution of Expert’s Interpretation | No |
Regulatory Template, Regulatory Summary and Behaviour Template
Material changes
The Country Manual has been reviewed to ensure that the content of all the documents remains accurate and up to date. We can confirm that there have been no material changes or modifications in the relevant Israeli regulation since the last update with an impact for banks that have received a Permit under Section 49A Securities Act.
Implications for business relations with third parties
Regarding local EAMs without a Permit under Section 49A Securities Act, it has been specified that it is forbidden to pass on trading orders to the foreign Bank (or to execute them), unless the EAM benefits from an exemption i.e. it provides its services exclusively to qualified clients or if transactions concern portfolio management services within the managed portfolio. On the other hand, general referral activities or activities delegated by the Bank to third parties (e.g. verification of a client’s identity, collection of KYC documents etc.) are not subject to a Permit requirement for the EAM.
It has also been clarified that if the EAM benefits from one of the above exemptions, the Bank is not required to include the EAM on its list of “external entities” defined under the Amendment to the General Permit Conditions under Section 49A Securities Law.
Regulatory Summary
This document has now a more user-friendly layout and reflects the changes 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 “ISRAEL PERMIT ALL” 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.
For more information, please contact us: info@brpsa.com
Geneva, October 1th, 2024