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The Digital Operational Resilience Act, adopted by the European Union in December 2021, requires full implementation by January 17, 2025. Developed in response to rising digital risks and the increasing dependence on technology within the financial sector, DORA aims to harmonize EU regulations on ICT risk management, incident reporting, resilience testing, and third-party risk management. This regulatory framework is designed to ensure that financial institutions can effectively manage and mitigate cyber threats, maintain continuity of critical operations, and protect the integrity of the financial system. In this article, we will discuss the principles of proportionality and due diligence, key components of DORA that guide financial entities in implementing these regulations according to the scale and complexity of their operations.
Assessing ICT-Related Dependencies
DORA introduces the principle of proportionality, a key concept that Compliance Officers must consider during the initial due diligence process. This principle mandates that
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I am Diego Ofano, a Compliance and Anti-Money Laundering professional based in Luxembourg. I serve as Conducting Officer and RC/MLRO for a financial institution, overseeing regulatory compliance for EU-domiciled funds. My responsibilities include AML/CFT frameworks, due diligence, regulatory advisory, and training. I regularly deal with complex regulatory and operational matters, with a focus on pragmatic and risk-based solutions in the investment funds industry.
I hold a Law Degree from the University of Bologna, a Master in European Business from ESCP, and certifications like CAMS, keeping me current in compliance and technology.
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