Vatican City – Country Manual Private Banking – Update 2021

Apr 1, 2021

Country Manuals Private Banking

VATICAN CITY OUT OF BANK’S COUNTRY OF ESTABLISHMENT (Def, RS, BT & RT)

Regulatory Template

Material changes
The Manual has been slightly reviewed to take account of an evolving interpretation of the applicable legal and regulatory framework. In particular, considering that the Italian supervisory authorities have now a stricter approach with regard to activities undertaken on-site, this would likely affect the approach followed by the Vatican supervisory authority for the same activities.
Without prejudice to the foregoing, we confirm that there have not been any relevant regulatory changes to the documents since the last update.

The main changes are reflected as follows:
– Providing a business card – This activity is now allowed during on-site meetings on an occasional basis and for socialising purposes only.
– Collecting relevant supporting documents and information – This activity is now a ‘grey zone’ when undertaken during on-site meetings upon request.
– Offering E-banking Services with Respect to an Existing Account – This activity passed from ‘grey zone /NO’ to ‘NO’.
– Reporting activities – Actively and passively undertaking reporting activities (providing account/deposit information and statements as well as reports on managed account performance) during on-site meetings is now a ‘grey zone’. Moreover, the Bank must in any case refrain from undertaking any other restricted activity (such as providing a client with investment advice).

Implications for business relations with third parties
There have been no substantial changes to the answers when a Bank co-operates with third parties.

Non-material changes
Certain comments have been slightly reworded (without introducing material changes) to reflect the new format of the document.
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 “VATICAN CITY” 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,