Chapter 4, Article 19 · Commission Implementing Decision (EU, Euratom) 2023/2825

Contents

Article 19Establishment of a High Level Risk and Compliance Policy#

1.The Chief Risk Officer shall draw up a High Level Risk and Compliance Policy that shall identify the principal risks to the financial interests of the Union arising from the implementation of the borrowing, debt management, liquidity management and lending operations. In this context, the Chief Risk Officer shall take into account the principles for risk recognition and assessment, according to which an effective internal control system identifies and continuously assesses the principal risks.

2.The High Level Risk and Compliance Policy shall set the strategic risk objectives and shall provide the overarching framework for the risk management guidelines applicable to borrowing, debt management, liquidity management and lending operations.

3.The High Level Risk and Compliance Policy shall identify all associated risks, including liquidity, market, funding, credit, counterparty and operational risks, arising from the implementation of the borrowing, debt management, liquidity management and lending operations. The High Level Risk and Compliance Policy shall set for each risk the high-level risk appetite, the general methodologies to measure the risk exposure, the monitoring and reporting requirements as well as the escalation mechanism to be taken in case of breaches or non-compliance. It shall verify the solidity of procedures needed to ensure the probity, integrity and transparency of those operations and shall limit any financial or operational risk appropriately.

4.The High Level Risk and Compliance Policy shall include the following rules and procedures:

(a)rules and procedures to be respected by persons who are responsible for the operational implementation and execution of the diversified funding strategy, and;

(b)rules and procedures to prevent money laundering, terrorist financing, execution of borrowing, debt management and lending operations by entities incorporated in or established in jurisdictions listed under the relevant policy on non-cooperative jurisdictions or that are identified as high-risk countries pursuant to Article 9(2) of Directive (EU) 2015/849 of the European Parliament and of the Council^note, or that do not effectively comply with Union or internationally agreed tax standards on transparency and exchange of information, breaches of sanction regimes and other relevant financial irregularities.

5.The High Level Risk and Compliance Policy shall be reviewed at least annually and revised if necessary.

6.The High Level Risk and Compliance Policy shall be submitted by the Chief Risk Officer to the Member of the College responsible for the Budget for approval.

Source: EUR-Lex, © European Union, 1998-2026. Reuse authorised under Decision 2011/833/EU.

Key facts

Type

Decision · Commission Implementing Decision (EU, Euratom) 2023/2825

Adopted

12 Dec 2023

In force

19 Dec 2023

Text current to

10 Dec 2025

Made by

Directorate-General for Budget, European Commission

Official

EUR-Lex 32023D2825 · ELI

Defined terms · 17

Show every defined term

auction
means the issuance process of the Union and Euratom debt securities based on competitive bids through an auction platform;
borrowing operations
means operations on the markets, in particular debt issuances to borrow, including roll-over borrowing;
debt management operations
means market operations related to the debt resulting from the borrowing operations to optimise the structure of the outstanding debt, to mitigate interest rate risk, to support the secondary market liquidity or to mitigate other financial risks;
derivatives
means derivatives as defined in Article 2(5) of Regulation (EU) No 648/2012 of the European Parliament and of the Council;
disbursement
means the passing of proceeds obtained through borrowing and debt management operations to finance repayable or non-repayable support to a beneficiary;
lending operations
means operations related to the implementation of loans and credit lines for financial assistance under Article 220 of the Financial Regulation;
liquidity management operations
means operations to manage the inflows and outflows of proceeds arising from borrowing and debt management operations in order to enable the cost-effective management of those amounts;
long-term funding
means funding by borrowing operations for a term of more than one year, excluding the amounts held on own account;
money market instruments
means such instruments as deposits, including term certificates of deposit, credit lines, money market mutual funds, exchange traded funds tracking money market indices, commercial papers, treasury bills, bonds maturing within one year, and securities lending and repurchase agreements, in accordance with the definition of ‘money-market instruments’ in Article 4(1), point (17) of Directive 2014/65/EU of the European Parliament and of the Council;
non-competitive auction allocation
means the issuance process whereby amounts of the Union and Euratom debt securities additional to the auctioned amounts are allocated to members of the primary dealer network established under Commission Decision (EU) 2023/1602 participating in the auction based on a set price, within a set period of time following an auction and by using, as appropriate, an auction platform to carry out the allocation.
programme authorising officer
means the authorising officer responsible, in accordance with Annex I to the Internal Rules established by Commission Decision C(2018) 5120, for the implementation of the budget lines of a financial assistance programme and a programme financed under Article 2(2) of Regulation (EU) 2020/2094, in so far as it implements measures referred to in Article 1(2) of that Regulation;
prudential cash holdings
means the amount of cash required to be held on the ECB cash account, ahead of upcoming payments for a determined period;
reverse repurchase transaction
means respectively repurchase transaction or reverse repurchase transaction as defined in Article 3(9) of Regulation (EU) 2015/2365 of the European Parliament and of the Council;
sell-buy back transaction
means respectively a buy-sell back transaction or sell-buy back transaction as defined in Article 3(8) of Regulation (EU) 2015/2365;
short-term funding
means funding by borrowing operations for a term below or equal to one year and the use of unsecured money market transactions and secured money market transactions;
swap
means swap as defined in Section 1, point 10, of Annex III to Commission Delegated Regulation (EU) 2017/583;
syndicated transaction
means a transaction whereby financing is offered by a group of lenders, referred to as a syndicate, to a single borrower;