Each case is different, and there may be many reasons for not issuing the favourable report, but in general terms the most frequent are usually the following:
- There are obligations established in the Law that have not been contemplated in the manual. To correct this deficiency, all the points of the Recommendations document on PBC-FT internal control measures must be taken into account ", which is located on the", Executive Service website," Reports and Publications "section.
- There are obligations established in the Law that are interpreted in an erroneous or confusing manner in the procedures manual (for example, confusion between DMO and communications by indication). It is necessary that the entity that is going to be constituted has an adequate knowledge of all the obligations established by Law 10/2010.
A greater practical definition of the application of the procedures is lacking. The manual should not be a mere transcription of the legislation, but should describe how the obligations established by the Law will be complied with in practice.