Country Manual Private Banking
Nicaragua
BRP has updated its Country Manual Private Banking for Nicaragua out of Bank’s Country of Establishment (DEF, RS, BT & RT)
| Source of changes | Answers |
|---|---|
| Law / Regulation | No |
| New Position of the Authorities | No |
| Evolution of Expert’s Interpretation | Yes |
Regulatory Template, Regulatory Summary and Behaviour Template
Material changes
The country manual has been updated to reflect the evolution of the expert’s interpretation of the regulatory framework in Nicaragua regarding the rules applicable to a foreign bank’s use of a local entity.
Now following the same approach of the third party in Nicaragua, pre-contractual activities such as provision of banking and investment contracts as well as assistance with completion of forms and dispatch of signed documents by the local entity to the foreign Bank are to be avoided, since these activities are a strong indicator of an agency relationship between the local entity and the Bank, resulting in the performance of habitual or regular business on behalf of the foreign Bank in Nicaragua and triggering a license requirement.
Non-material changes
Several comments have been slightly reworded (without introducing material changes) to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.
Regulatory Summary
This document 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 “NICARAGUA” 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, January 6th, 2025