Question
Is an institution, that is a subsidiary of a holding company which, in turn, owns several financial subsidiaries, not considered as a group for the purposes of the Delegated Regulation, since their parent company does not fall within the definition of a financial entity set out in Article 3 of Directive (EU) 2015/849 (AMLD)?
Background on the question
This questions has been raised in a supervisory action focused on the application of the Delegated Regulation. There has been the case of an institution that is a subsidiary of a holding company which, in turn, owns several financial subsidiaries. The institution considers that they are not a group for the purposes of the Delegated Regulation, since their parent company does not fall within the definition of a financial entity set out in Article 3 of Directive (EU) 2015/849 (AMLD).