. the bcbs assessment framework suggests that local regulators are entrusted with the task to set up their own methodology for the process of identifying which banks to be considered as d - sibs. nonetheless, some general guidelines on the subject from bcbs would be helpful, and they will make the exercise more consistent region - wide. 2. central banks in our region could develop a peer - group approach for this exercise so they could learn from each other. 3. it seems that the d - sibs proposal is restricted to banks. would non - bank financial institutions ( nbsfis ) be considered? would the assessment of systemic importance cover subsidiaries ( and not branches ) of banking groups. 4. the assessment framework also suggest there will be a mix of qualitative and quantitative judgments for each d - sib. with the general guidelines from bcbs, it would be the responsibility of the local authority to assign the appropriate weights to the qualitative vs. the quantitative judgments. 5. while waiting for the final version of bcbs document, central banks in our region could start working on the identification exercise of d - sibs, taking into account local considerations, learning from countries of similar financial systems, and benefiting from peer - reviews. iii. higher loss absorbency ( hla ) 1. as in the g - sibs framework, d - sibs will be required to hold additional common equity tier 1 capital ( cet1 ) to meet their hla requirements, which eventually support capital conservation of the basel iii capital framework. it is a positive development that national regulators are given the authority to decide on the appropriate level of additional cet1, consistent with each bank ’ s systemic importance. however bis central bankers ’ speeches there is some concern that the proposed hla would just duplicate the already in place country - specific prudential measures implemented in the region, which would mean that the d - sib ’ s cost of doing business will go up. for example, in the uae we impose the following capital ratios : – tier 1 core capital : a minimum of 8 % ( actual is : 14. 5 % ) – tier 1 and other tiers : a minimum of 12 % ( actual is : 20. 5 % ) 2. however, it is suggested that local regulators should allow identified d - sibs a comprehensive grace period to fully comply with the hla requirements. 3. as local debt markets are at an infancy stage in many countries in the region, this would

sultan bin nasser al - suwaidi : encountering money laundering and terrorist financing inaugural speech by his excellency sultan bin nasser al - suwaidi, governor of the central bank of the united arab emirates and chairman of the national anti - money laundering committee in the united arab emirates, at the joint seminar of the national anti - money laundering committee and the serious organized crime agency ( soca ) a€ “ uk, al - ain, 2 july 2006. * * * your excellencies, honored guests, fellow members of the national anti - money laundering committee, ladies & gentlemen, after greetings i would like to give you all a whole hearted welcome at the joint seminar of the national anti - money laundering committee in the uae and serious organized crimes agency ( soca ) - uk which is held today in the city of al - ain, in order to discuss some topics relating to : " encountering financial crimes ; including money laundering and terrorist financing ". the meeting of your esteemed committee this morning, prior to the joint seminar, signifies the important role the committee undertakes in accordance with federal law no. ( 4 ) for the year 2002 regarding criminalization of money laundering, and the role played by fellow members of the committee in facilitating exchange of information, and ensuring coordination between the bodies they represent, and generally representing the uae in issues and relating to combating money laundering and terrorist financing. at the outset of the joint seminar, i'm also pleased to welcome mr. paul evans, the executive director of the serious organized crimes agency ( soca ) and the accompanying delegation, and also mr. robert dean, the deputy head of the diplomatic mission of the uk in abu dhabi, for their participation at this meeting, and for their appreciated coordination regarding the issues which would be discussed today. your excellencies, ladies & gentiemen, we highly appreciate the significant role of the national anti - money laundering committee in the uae in the area of international cooperation and their keen interest to learn of the best practices for combating money laundering and terrorist financing, and the techniques applied in this respect by friendly countries. delegations from your esteemed committee have visited the uk several times, and received fruitful cooperation from the competent authorities in the uk, including the serious organized crimes agency ( soca ). we highly appreciate, as well, the attitude of the authorities in the uk, particularly the serious organized crimes agency ( soca ) for their continuous liaison with the authorities in the uae