# Finance / Banking Lexicon

English terminology for finance and banking documents: project finance security packages, facility agreements, pledges, mortgages, bonds, loan agreements, intercreditor agreements, syndicated facilities, Basel III/CRR, AML/KYC, sanctions compliance, banking licenses, and related instruments. Unified lexicon covering both project finance / security (formerly `finance.md`) and general banking / regulatory (formerly `banking-regulatory.md`).

> **Per-language sub-lexicon note.** This English reference file covers finance & banking only; trading & capital-markets terminology lives in `references/trading-capital-markets.md`. In the per-language sub-lexicons the two domains are consolidated: `sub-lexicons/<language>-finance-banking.md` covers both. When working on a capital-markets document, read both English reference files but only the single per-language sub-lexicon.

## Core Finance Terms

| Correct English term | Usage / meaning | Avoid |
|---|---|---|
| facility agreement | The agreement governing a loan/credit facility (LMA standard) | "financing agreement", "loan contract" |
| loan agreement | Specific agreement for a direct (typically bilateral) loan | "loan facility" (if framework); "credit contract" (informal) |
| facility | The credit line itself (Term Facility, VAT Facility, DSR Facility) | "financing", "loan" (in PF context) |
| lender | The bank or institution providing the facility | "financing bank" |
| borrower | The party receiving the facility | — |
| secured party / secured parties | The party/parties benefiting from the security | "secured creditor" (acceptable but less standard in LMA) |
| security interest | Any right in an asset granted to secure an obligation — the umbrella term covering pledges, mortgages, charges, liens, etc. | — |
| security package | The entire set of security documents and security interests in a transaction | — |
| enforcement event | An event triggering the right to enforce security | "cause of enforcement" |
| event of default | A breach or occurrence giving rise to acceleration/termination rights | "relevant event" |
| potential event of default | An event that would become an event of default with notice or time | "potential relevant event" |
| security period | The period during which security remains in force | "guarantee period" |
| maximum secured amount | The cap on amounts secured | "maximum guaranteed amount" |
| subject matter of the security | The assets or rights that are secured | "subject matter of guarantee" |
| perfection | The process of making a security interest enforceable against third parties, typically by registration or filing | — |
| mortgage loan | Loan secured by real estate charge/deed of trust | "home loan" (too informal); "real estate loan" (less specific) |
| unsecured loan | Loan with no collateral pledged | "clean loan"; "signature loan" (informal) |
| credit facility / overdraft facility | Pre-approved amount available for borrowing (typically short-term) | "overdraft account"; "credit line" (acceptable but "facility" is standard) |
| overdraft | Temporary deficiency in account balance (may be unauthorized) | "overdraw" (verb form) |
| letter of credit (L/C) | Documentary instrument guaranteeing payment against presentation of shipping docs | "credit letter" (imprecise) |
| documentary credit | Credit secured by documents of title (bills of lading, etc.) | "trade credit" (too broad); "commercial credit" (imprecise) |
| bank guarantee | Undertaking by bank to pay on demand if beneficiary makes claim | "bank's guarantee" (grammatically acceptable) |
| comfort letter / letter of awareness | Informal representation by parent company regarding subsidiary's performance | "letter of comfort" (acceptable); "parent company letter" (less formal) |

## Facility Types, Drawdown and Financial Instruments

| Correct English term | Usage / meaning | Avoid |
|---|---|---|
| term facility | A non-revolving credit facility drawn down and repaid over time | "cash facility" |
| revolving facility | A credit facility that can be drawn, repaid, and re-drawn | — |
| credit facility | Generic term for a lending arrangement | "credit line" (acceptable informally) |
| syndicated facility | Facility where multiple lenders participate, typically arranged by arranger/agent | "syndication" (process, not product) |
| club deal | Facility arranged for multiple lenders without formal syndication structure | "syndicated deal" (less precise) |
| commitment | The maximum amount a lender has agreed to make available (LMA defined term) | Do not confuse with the colloquial meaning |
| drawdown / utilization | The act of borrowing funds under a facility | "take-down" (less formal) |
| utilisation request (UK) / utilization request (US) | A formal notice requesting a drawdown | — |
| interest rate | Rate of interest payable on the facility | — |
| margin | The spread added to the benchmark/reference interest rate | — |
| default interest | Increased interest rate applicable after a default | — |
| principal amount | The face value of the loan, excluding interest | — |
| repayment schedule | The timetable for repaying principal | "repayment plan" |
| amortisation (UK) / amortization (US) | Scheduled repayment of principal over time | — |
| prepayment | Early voluntary repayment (may incur penalties) | "early repayment" (acceptable); "redemption" (different legal meaning) |
| refinancing | Replacement of facility with new facility (often with new lenders) | "refi" (informal) |
| financial covenants | Financial ratios/thresholds the borrower must maintain | — |
| material adverse change (MAC) / material adverse effect (MAE) | Event or circumstance that materially adversely affects borrower's ability to perform obligations | "Adverse change" (too vague) |
| intercreditor agreement | Agreement between creditors governing their relative rights | "creditor agreement" |
| subordination | The ranking of one creditor's claims below another's | "subordinated position" |
| pari passu ranking | Equal ranking between claims | "pro-rata" |
| senior debt | Debt with priority payment over subordinated debt | "senior tranche" (if tiered) |
| subordinated debt / mezzanine debt | Debt ranking behind senior but potentially ahead of equity | "junior debt"; "sub-debt" (informal) |
| tranche | Separate portion of facility with different terms (e.g., Term A, Term B) | "slice" (informal) |
| negative pledge | Undertaking not to create security over assets in favor of third parties | — |
| mandatory prepayment | Required early repayment triggered by specified events | — |
| voluntary prepayment | Optional early repayment at the borrower's election | — |
| clean-down period | Requirement for revolving facility to be fully repaid for specified period | — |
| change of control | **Canonical definition** — change in ownership or effective control of a contracting party. Typical triggers by context: EoD/mandatory prepayment (this file); termination/consent right (ip-it-technology, ndas-service-agreements, consumer-retail); authority consent (public-procurement, energy-infrastructure); assignment restriction (real-estate); coverage continuity issue (transport-and-insurance); accelerated vesting (employment); cross-refer to corporate-ma-jv for put rights. | "change control" (refers to scope/variation); ownership change (too vague); acquisition (narrower — CoC can also occur by internal restructuring) |
| conditions precedent | Conditions that must be satisfied before first drawdown | "suspensive conditions" |
| representations and warranties | Statements of fact and promises by the borrower | "declarations and warranties" |
| recitals | The introductory section of the agreement | "preambles", "premises" |
| schedules | Attachments to the agreement | "annexes" (acceptable in EU/international) |
| waiver | Creditor's agreement to overlook breach (typically documented separately) | "forbearance" (less technical) |
| amendment and restatement | Full replacement of the facility agreement in amended form | "modification" (less formal) |
| commitment fee | Fee payable on undrawn portion of committed facility | "standby fee" (less standard) |
| arrangement fee | Upfront fee payable to arranger for structuring and arranging facility | "front-end fee" (informal) |
| information undertaking | Borrower's obligation to provide periodic financial information | "Reporting obligation" (less precise in LMA context) |
| majority lenders | Lenders controlling requisite percentage to approve amendments/waivers | "lenders in majority" |

## Security-Specific Terms

| Correct English term | Usage / meaning | Avoid |
|---|---|---|
| pledge | Security interest over movable property or rights (civil law concept with broad equivalence across jurisdictions) | — |
| mortgage | Security interest over immovable property (real estate) | — |
| special lien | Statutory priority right over specific assets | "special privilege" |
| deed of special lien | The document creating a special lien | "deed of establishment of privilege" |
| assignment of receivables | Transfer of the right to receive payments as security | — |
| assignment by way of security | Assignment made for security purposes (not outright transfer) | — |
| guarantee | A secondary obligation — the guarantor's liability is contingent on the principal debtor's default. Accessory in nature: it follows the underlying obligation. | Confusing with "on-demand guarantee" (see below) |
| on-demand guarantee / demand guarantee | An independent, primary obligation — payable on demand without proof of the principal debtor's default. Not accessory. | "autonomous guarantee at first demand" (calque) |
| surety / suretyship | A co-extensive obligation — the surety is jointly and severally liable with the principal debtor. Stricter than a guarantee. | Treating "surety" and "guarantee" as synonyms |
| enforcement of the security | The process of realizing the security interest | — |
| lien / charge | A right over assets as security for a debt | — |
| encumbrance | Any third-party right burdening an asset | — |
| pledge of quotas | Pledge over ownership interests in an LLC-type entity | — |
| share pledge | Pledge over shares in a company | — |
| account pledge | Pledge over a bank account and its balances | — |
| charged account / pledged account / blocked account | A bank account subject to a security interest | — |
| voting rights | The right to vote attached to pledged shares/quotas | — |
| lien assets | The specific assets subject to a lien | "privilege subject matter" |
| release of the lien | Discharge/cancellation of a lien | "cancellation of privilege" |
| registration and publicity | The process of recording security interests in public registers | "transcription and publication" |

## English-Law Security Concepts

These terms are specific to English-law finance documents. Use them only when the source document's security structure genuinely maps to the English-law concept. Civil law security concepts often do not map neatly to common law categories.

| Correct English term | Usage / meaning | Notes |
|---|---|---|
| debenture | A document creating fixed and floating charges over all or substantially all of a company's assets | Standard English-law security instrument in LMA deals |
| fixed charge | A charge attaching to specific, identified assets (the chargor cannot deal with them freely) | Maps well to civil law pledges over specific assets |
| floating charge | A charge hovering over a class of changing assets (e.g., inventory, receivables) until crystallization | No direct civil law equivalent — use only where the source concept involves security over a fluctuating pool of assets |
| crystallization | The moment a floating charge converts into a fixed charge over specific assets | — |
| security trustee | The entity holding security on trust for the benefit of all lenders (English-law PF structures) | Distinguished from "security agent" (which acts as agent, not trustee) |

## Project Finance Cashflow and Reserve Terms

| Correct English term | Usage / meaning | Avoid |
|---|---|---|
| cash waterfall / cash cascade | The contractual priority order in which project revenues are applied | "payment order" |
| cash sweep | Mechanism requiring excess cash flow to be applied to prepayment of the facility | — |
| debt service reserve account (DSRA) | Reserve account holding funds to cover debt service if project revenues are insufficient | — |
| maintenance reserve account (MRA) | Reserve account for major maintenance expenditure | — |
| distribution account | Account from which equity distributions are paid | — |
| step-in rights | The lenders' contractual right to step in and take over management of a project contract if the borrower defaults | "substitution rights" (acceptable in some jurisdictions) |

## Syndication, Transfer and Assignment

| Correct English term | Usage / meaning | Avoid |
|---|---|---|
| syndication agreement | Agreement among arrangers and lenders governing facility participation | "master syndication agreement" |
| transfer of participation | Sale or transfer of lender's participation to another lender | "lender exit" (informal) |
| assignment of claim / debt assignment | Legal transfer of loan rights and obligations to assignee | "novation" (different legal effect — replaces creditor) |
| sub-participation | Lender's participation in another lender's position, without borrower consent/knowledge | "participation sharing" |
| consent | Lender/agent approval for specific action | "approval" (acceptable) |

## Party Roles

| Correct English term | Usage / meaning | Avoid |
|---|---|---|
| grantor | The party granting the security interest | — |
| secured party | The party benefiting from the security interest | "beneficiary" (ambiguous — see note below) |
| lender | The institution providing the credit facility | "financing bank" |
| agent / facility agent | The bank acting as administrative agent for a lending syndicate | — |
| security agent | The agent holding security on behalf of all lenders | — |
| notary | The public official authenticating the deed | — |
| guarantor | The party providing a guarantee | — |
| assigned debtor | The debtor whose obligations have been assigned | — |
| borrower | The party receiving funds under a facility | — |
| arranger / mandated lead arranger (MLA) | The bank arranging the syndication | "underwriter" (different role) |
| depositary / custodian bank | Bank holding securities or funds on behalf of customers | "trustee" (legal distinction) |
| correspondent bank | Bank providing settlement/clearing services in foreign jurisdictions | "clearing bank" |

## Regulatory and Prudential Terms

| Correct English term | Usage / meaning | Avoid |
|---|---|---|
| banking supervision | Oversight of banking institutions by regulatory authorities | "prudential supervision" |
| supervisory authority | Regulatory body overseeing banking/financial institutions | "regulator" (less formal) |
| national central bank / national banking regulator | Country-specific monetary authority and/or banking supervisor | "central bank" (too generic without country) |
| European Central Bank (ECB) | Monetary authority for euro area (also banking supervisor via SSM) | "central bank" (too generic) |
| Single Supervisory Mechanism (SSM) | ECB-led arrangement for supervising significant euro area banks | "unified supervision" (less precise) |
| Single Resolution Mechanism (SRM) | EU-level resolution authority for failing banks in participating states | "resolution authority" (less precise) |
| banking license | Regulatory authorization to conduct banking business | "bank charter" (US-specific) |
| capital requirements | Regulatory minimum capital levels | "capital adequacy requirements" (Basel III language) |
| own funds | Capital recognized for regulatory purposes (sum of Tier 1, Tier 2) | "equity" (accounting term) |
| Common Equity Tier 1 (CET1) | Highest-quality capital | "core capital" (informal) |
| Additional Tier 1 (AT1) | Subordinated capital (contingent convertible, hybrid debt) | "Tier 1 hybrid" (informal) |
| Tier 2 (T2) | Subordinated capital with longer maturity/subordination than AT1 | — |
| solvency ratio | Ratio of own funds to risk-weighted assets | "capital ratio" (acceptable) |
| leverage ratio | Ratio of Tier 1 capital to total assets (non-risk-weighted) | "simple leverage ratio" (informal) |
| capital conservation buffer | Capital above minimum requirement that bank must maintain | "buffer capital" |
| countercyclical buffer | Additional buffer applied during credit booms | "CCB" (abbreviation acceptable) |
| systemic risk buffer | Additional capital for systemically important institutions | "SRB" |
| minimum requirement for own funds and eligible liabilities (MREL) | Requirement for banks to maintain own funds + bail-in-eligible liabilities for resolution | "bail-in capacity" (related but not identical) |
| total loss-absorbing capacity (TLAC) | International standard for G-SIBs | "loss-absorbing capacity" |
| stress test | Regulatory assessment of bank solvency under adverse scenarios | — |
| supervisory review and evaluation process (SREP) | ECB/SSM assessment of individual bank capital adequacy | "supervisory review" (less formal) |
| Capital Requirements Regulation (CRR) | EU Regulation (EU) No. 575/2013 | "capital regulation" (vague) |
| Capital Requirements Directive (CRD) | EU Directive 2013/36/EU (governance, remuneration, sanctions) | "capital directive" (vague) |
| Basel III | International prudential framework | "Basel 3" (non-standard) |
| bail-in | Regulatory power to convert bank liabilities into equity or cancel them | "depositor haircut" (imprecise) |
| resolution plan / living will | Bank's documented plan for rapid orderly resolution | "resolution strategy" |
| passporting | EU banking license right to operate in other EU member states | "EU passport right" |
| ring-fencing | Structural separation of retail/payment banking from trading/investment banking | "banking separation" (less technical) |

## AML/KYC Terms

| Correct English term | Usage / meaning | Avoid |
|---|---|---|
| anti-money laundering (AML) | Regulatory framework preventing financial system use for illicit proceeds | "antimoney laundering" |
| money laundering | Process of disguising origin of illicit funds through financial system | "funds laundering" |
| terrorist financing | Providing financial support to designated terrorist entities/individuals | "terrorism financing" |
| customer due diligence (CDD) | KYC/AML assessment of customers' identity and beneficial ownership | "client verification" |
| enhanced due diligence (EDD) | Heightened CDD for higher-risk customers | "enhanced KYC" |
| simplified due diligence (SDD) | Reduced CDD standards for low-risk customers | "reduced KYC" |
| know your customer (KYC) | General standard for identifying and understanding customers | "customer verification" |
| beneficial owner | Natural person ultimately owning/controlling entity | "true owner" |
| politically exposed person (PEP) | Individual in high public office or close associate | "high-ranking official" |
| suspicious transaction report (STR) | Report filed by financial institution regarding suspicious activity | "alert" (too vague) |
| Financial Intelligence Unit (FIU) | Government agency receiving and analyzing AML reports | "financial intelligence center" |
| reporting obligation | Legal requirement to report suspicious transactions, beneficial ownership | "disclosure obligation" |
| beneficial ownership register | Public/semi-public database of ultimate beneficial owners | "UBO register" |
| EU Anti-Money Laundering Directive (AMLD) | Series of EU directives (AMLD4, AMLD5, AMLD6, upcoming AMLA) | "AML directive" (imprecise) |

## Sanctions Terms

| Correct English term | Usage / meaning | Avoid |
|---|---|---|
| sanctions / restrictive measures | Government-imposed financial/trade restrictions on persons, entities, jurisdictions | "embargo" (specific type) |
| embargo | Trade restriction prohibiting commerce with specified country/entity | "commercial embargo" |
| sanctions list / designated persons list | Official government register of sanctioned persons/entities | "target list" (informal) |
| SDN List (Specially Designated Nationals) | US OFAC list of sanctioned individuals and entities | — |
| asset freeze | Prohibition on access/transfer of assets of sanctioned person | "blocked assets" (result-focused) |
| prohibition on making funds available | Sanctions restriction preventing financial transfers to/for sanctioned party | "payment prohibition" |
| sanctioned person / designated person | Individual or entity subject to sanctions measures | "listed person" |
| sanctions screening | Process of checking counterparties against sanctions lists | "sanctions check" |
| license / authorization (sanctions context) | OFAC/government permission to conduct otherwise prohibited transaction | — |
| Office of Foreign Assets Control (OFAC) | US Treasury agency implementing US sanctions | "US OFAC" (redundant) |
| EU Sanctions Regulation | EU Regulation implementing sanctions | "EU sanctions" (too generic) |

## Payment and Settlement Terms

| Correct English term | Usage / meaning | Avoid |
|---|---|---|
| payment system | Infrastructure for processing and settling payments (SEPA, SWIFT, TARGET2) | "clearing system" (overlapping) |
| bank transfer / wire transfer | Electronic transfer of funds from one account to another | "wire" (informal) |
| SEPA credit transfer | Credit transfer within Single Euro Payments Area | "euro payment" (imprecise) |
| SEPA direct debit | Debit transfer within SEPA authorized by payer | "direct debit" (pre-SEPA) |
| SWIFT | Society for Worldwide Interbank Financial Telecommunication | — |
| BIC code | Bank Identifier Code | "SWIFT code" (overlapping) |
| IBAN | International Bank Account Number | — |
| interbank clearing | Process of matching and settling payments between banks | "bank clearing" |
| real-time gross settlement (RTGS) | System settling payments individually and immediately | "gross settlement" |
| TARGET2 | Trans-European Automated Real-time Gross settlement Express Transfer system 2 | "TARGET system" |
| electronic money / e-money | Digital representation of value stored electronically | "virtual currency" (may refer to crypto) |
| payment institution | Entity licensed to provide payment services under PSD2 | "payment service institution" |
| Payment Services Directive (PSD2) | EU Directive 2015/2366 | — |

## Section Headings

| Correct English heading | Avoid |
|---|---|
| DEFINITIONS | "DEFINED TERMS"; "INTERPRETATION" (different purpose) |
| FACILITY / LOAN | "CREDIT"; "FINANCING" (less formal) |
| CREATION OF THE PLEDGE / MORTGAGE | "CONSTITUTION OF THE PLEDGE" |
| UTILIZATION / DRAWDOWN | "DRAWING" (informal) |
| REPAYMENT | "RETURN OF FUNDS" |
| INTEREST | "RATE OF INTEREST" |
| FEES | "CHARGES" |
| REPRESENTATIONS AND WARRANTIES | "DECLARATIONS AND WARRANTIES" |
| UNDERTAKINGS | "OBLIGATIONS", "COMMITMENTS" |
| EVENTS OF DEFAULT | "DEFAULT"; "TERMINATION EVENTS" |
| ENFORCEMENT EVENTS | "CAUSES OF ENFORCEMENT" |
| PREPAYMENT | — |
| CONDITIONS PRECEDENT | "SUSPENSIVE CONDITIONS" |
| SECURITY | "GUARANTEES" (different legal mechanism) |
| AGENCY PROVISIONS | "AGENT TERMS" |
| GOVERNING LAW AND JURISDICTION | "APPLICABLE LAW AND COMPETENT COURT" |
| NOTICES | "COMMUNICATIONS" |
| TAXES, DUTIES AND EXPENSES | — |
| MISCELLANEOUS | — |

## Legal Formulae

| Correct English term | Usage / meaning | Avoid |
|---|---|---|
| non-exclusive security | Security that does not exhaust the creditor's remedies | "non-exhaustive guarantee" |
| whether by way of universal or individual succession | Standard English formulation for transfers by inheritance or assignment | — |
| successors and assigns | Standard phrase for all who may succeed to rights/obligations | "successors and those who acquired title" |
| not registered in any public register | Description of unregistered assets | — |
| assets (commercial) / estate (insolvency) | See general-legal.md for guidance | "patrimony", "heritage" |
| amendment of the Deed | Change to the security document | "modification of the Act" |

## Project Finance — Construction Cross-Over Terms

Terms that appear in construction/EPC contracts within a PF structure. Use PF-standard English to ensure consistency with the facility agreement and other finance documents.

| Correct English term | Usage / meaning | Avoid |
|---|---|---|
| finance parties / lenders | The lending syndicate | "financing institutions" |
| notice to proceed (NTP) | Formal notice authorizing the contractor to begin work | "commencement notice" |
| change in law | A change in applicable legislation affecting the project | "legislative changes" |
| termination for convenience | The employer's right to terminate without cause | "withdrawal" |
| termination for default | Termination triggered by the contractor's breach | "resolution for non-performance" |
| direct agreement | Agreement between lenders and a project counterparty, documenting step-in rights and other lender protections | — |
| project schedule | The program/timetable for the works | "timing plan" |
| acceptance test | The test to verify the works meet specifications | "testing" (too vague) |
| liquidated damages (LDs) | Pre-agreed damages for delay or underperformance | "penalties" |
| mandatory variations | Variations required by law or regulation | "necessary variations" |
| discretionary variations | Variations at the employer's option | "optional changes" |

### Design Stage Terminology (Critical)

The three-stage design hierarchy must be translated correctly. Getting these wrong is a material error that changes the contractual meaning.

| Design stage | Correct English | Avoid |
|---|---|---|
| Stage 1 (conceptual) | preliminary design | "preliminary project" |
| Stage 2 (intermediate) | detailed design | "definitive project" (calque), "preliminary design" (WRONG STAGE) |
| Stage 3 (construction-ready) | construction design | "executive project" (calque), "detailed design" (reserve for Stage 2) |

## Notes

- **"Beneficiary" is ambiguous in security contexts**: The "beneficiary of the facility" is the borrower (who receives the money), but the "beneficiary of the security" is the secured party (who holds the security interest). Always disambiguate based on context. Never translate both as "borrower".

- **LMA standard**: English finance documents generally follow Loan Market Association (LMA) conventions. Align terminology with LMA standards where possible.

- **Loan vs. facility agreement**: Many source languages distinguish between a specific loan contract (bilateral, principal sum) and a broader credit facility. In English, use "facility agreement" (LMA standard) for syndicated/structured lending, and "loan agreement" for simple bilateral loans. Do not force source-language distinctions onto English; translate based on document structure and economic substance.

- **Project finance specifics**: In PF documentation, "Facility" always refers to a specific credit line (Term Facility, VAT Facility, DSR Facility). Never use "Loan" — "Facility" is the market standard.

- **"Article" vs "Clause" vs "Section"**: Use "Section" (US default) or "Clause" (UK / LMA tradition) for internal cross-references within the document. Keep "Article" only when referring to legislation.

- **Civil law vs common law security**: Many civil law security concepts (e.g., the Italian "privilegio speciale", the French "nantissement", the German "Sicherungsübereignung") do not map neatly to English-law categories. When translating, use the closest English-law term only if the concepts are genuinely equivalent. If not, use a descriptive English translation and consider a translator's note. Never force-fit a common law term onto a fundamentally different civil law concept.

- **National banking legislation**: When translating references to national banking codes or consolidated statutes, provide the official English translation on first mention followed by the original-language citation in parentheses. Sub-lexicon provides source-language mappings.

- **Capital requirements terminology**: Use exact Basel III/CRR terminology (CET1, AT1, T2, MREL, TLAC, SREP). These are internationally standardized. Do not paraphrase or translate abbreviations — they are used identically across jurisdictions.

- **EU regulatory framework**: EU directives/regulations (CRR, CRD, AMLD, PSD2) are multinational standards and retained in main English-only lexicon (not sub-lexicon). National-specific authorities and legislation go to sub-lexicon only.

- **AML directive versioning**: EU AML framework is evolving. Documents may reference AMLD4 (2015), AMLD5 (2018), AMLD6 (2022), or upcoming AML Regulation (AMLA). Always confirm which version applies and note in translation.

- **Bail-in and resolution**: "Bail-in" is EU-specific recovery/resolution tool under Banking Union framework (SRM/SSM). Distinct from US bankruptcy/receivership. "Resolution plan" / "living will" = required documentation of bank's failure strategy.

- **Passporting and ring-fencing**: "Passporting" = EU banking license right (post-Brexit, applies within EU only, not UK). "Ring-fencing" = UK Vickers Report recommendation (implemented in UK, differs from EU structural separation proposals).

- **US vs UK English**: This lexicon uses US conventions by default (e.g., "recognized", "license", "organization", "utilization"). UK alternatives noted where material (e.g., US "authorization" vs UK "authorisation").
