Lessons for implementing Binding Corporate Rules from the approval of JP Morgan Chase's programme
summary
Describes a five-year process to get Binding Corporate Rules approved for JP Morgan, showing regulators accept diversified liability so each business line covers its own subsidiaries rather than a single European HQ; BCR scope is clarified to cover only transfers outside the EU; an FAQ mechanism resolves practical points; the burden of proof is narrowed so claimants must first substantiate complaints before the firm must disprove them; working early as a test case lets the company influence regulator expectations.
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