The unions that group the national financial sector presented their observations and proposals for the modification of some articles of the bill that regulates the National Intelligence Directorate (DNI).
They do so with the intention that the legislative piece can fulfill its purpose of strengthening national security, safeguarding the rights of citizens, the stability of the financial sector and the national economy.
The communication was sent to the president of the Chamber of Deputies, Alfredo Pacheco, under the signature of the Association of Multiple Banks of the Dominican Republic (ABA), the Association of Savings and Credit Banks and Credit Corporations (ABANCORD), the League Dominican Association of Savings and Loans, Inc. (Lidaapi) and the Dominican Association of Foreign Exchange Intermediaries, INC. (Adochange).
In the document, the unions highlighted the contribution that this bill constitutes for the institutional framework in the Dominican Republic, helping the State to have effective and specialized intelligence services, capable of facing current challenges to guarantee security, stability and national sovereignty, as well as the integrity of its heritage.
However, they pointed out that there are some provisions contained in the piece that, they understand, must be carefully reviewed by the Legislative Power, in order to adapt them to a wording that safeguards legislative harmony and that seeks an effective and reasonable application of this initiative. legal.
They warned that, if the current wording remains, it could cause significant damage to the financial system, injuring, in addition, fundamental and constitutionally protected rights in the country.
They suggest adding to the piece that, in the case of Financial Intermediation Entities (EIFs) (which are already regulated, supervised and audited by the agencies that make up the Monetary and Financial Authority), the information is requested via the Superintendency of Banks, in order to preserve the confidentiality obligation that they must comply with, in accordance with article 56 literal b, of Law number. 183-02, modified by Law no. 249-17.
They point out that, with the incorporation of this aspect, any distortion or risk that could arise from indiscriminate access to EIF information would be eliminated, which would affect the stability of the financial system that is based on trust.
They maintain that, in turn, it would guarantee the right to protection of personal data and privacy of individuals, as established by the Dominican Constitution.
Additionally, they suggest incorporating aspects that differentiate the different degrees of confidentiality and information security classification or the process of “declassification” of confidential or reserved information, it was reported in a press document released by the Association of Multiple Banks of the Dominican Republic (ABA).
They propose that, in addition to the coordination exercised by the DNI, a collegiate body be formed to be in charge of guiding and supervising the country’s intelligence and counterintelligence activities.
Another of the suggestions contained in the document sent to the Lower House is that the bill expand more specifically on the scope of the principles that support the National Intelligence Directorate, as well as the role that these play within the limits of its action, in such a way that they base and sustain the norm and the bases on which the law is based.
Additionally, they propose that new principles be incorporated such as: due process, legality and restricted circulation.
Finally, the unions appealed to the understanding of the legislators who study the piece, around the detailed aspects in the communication.
