Subject: RE: Clarification on Common Equity Tier 1 (Article 36) – Treatment of Current Year Profit
From: "rahapesu - RAB" <[email-masked]>
To: "'Liliana Neves Vilas Boas'" <[email-masked]>
Date: Wed, 12 Nov 2025 16:32:18 +0200

Dear Liliana Neves Vilas Boas,

Thank you for contacting the Financial Intelligence Unit of Estonia. In
your 30.10.2025 letter, you requested for clarification regarding the
treatment of the current financial year’s result in the calculation of Own
Funds, specifically under the “Deductions from Common Equity Tier 1 items”
as set out in Article 36 of the Regulation.

According to EU Regulation 575/2013 Article 36 (1) a), institutions shall
deduct losses for the current financial year from Common Equity Tier 1
items. Losses for the current financial year means losses for the entire
period (e.g. 01.01.2024 – 31.12.2024). The regulation specifically states
that only losses are deductible, meaning that profits must still be taken
into account in the calculation of Own Funds.

We hope that we have answered your questions.

Kind regards,

Rahapesu Andmebüroo | Estonian Financial Intelligence Unit
Tel +372 696 0500 | Pronksi 12, Tallinn |  <https://www.fiu.ee/>
www.fiu.ee

From: Liliana Neves Vilas Boas <[email-masked]>
Sent: Thursday, October 30, 2025 7:20 PM
To: rahapesu - RAB <[email-masked]>
Cc: Internal - Compliance Team* <[email-masked]>; xMoney Finance
<[email-masked]>
Subject: Clarification on Common Equity Tier 1 (Article 36) – Treatment of
Current Year Profit

Tähelepanu! Tegemist on välisvõrgust saabunud kirjaga.
Tundmatu saatja korral palume linke ja faile mitte avada.

Dear Rahapesu,

I am writing to request clarification regarding the treatment of the
current financial year’s result in the calculation of Own Funds,
specifically under the “Deductions from Common Equity Tier 1 items” as set
out in Article 36 of the Regulation.

Article 36(1)(a) states that institutions shall deduct “losses for the
current financial year” from Common Equity Tier 1 items.
Our question concerns the case where the institution presents a profit in
the current financial year:
In such a situation, should any amount be considered or deducted under
this point, or would the deduction apply only when there are current-year
losses?

Your guidance on the correct interpretation would be greatly appreciated.

Sincerely,

Liliana Neves Vilas Boas

Finance Manager |  <http://www.xmoney.com/> xMoney.com
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