Documentation of the anti-money laundering and anti-terrorist financing (AML) system
For our client, during regular legal advice, we developed documentation for an anti-money laundering and counter-terrorist financing system (hereinafter “AML/TF system”, maximum penalty for violating those laws may result in financial penalty up to 5 million EUR).
The project was initiated in connection with the dynamic growth of the client’s business, the introduction of the provision of new payment services and new types of money laundering or terrorist financing risks, faced by the client.
The development of the AML/TF system involved a project team consisting of the client’s ICT staff, customer service staff and external providers of innovative tolls for verification of identity of the users. In the process of implementation the Company’s management was also significantly involved.
The firm developed comprehensive documentation consisting of the main procedure including the principles of an anti-money laundering and counter-terrorist financing. We also drafted additional documentation such as:
- the procedure of the know you customer, and know your business;
- the procedure for reporting violations to the General Inspector of Financial Information;
- the procedure for storing data collected as part of the KYC/KYB process and transaction data and the rules for cooperation with external entities.
During the course of the project, we took into account the latest guidelines of:
- the Financial Supervisory Commission;
- the General Inspector of Financial Information;
- and the European Banking Authority on AML/CFT and included guidelines in the procedure.
As a part of the project’s implementation, we also developed guidelines for employees on how to monitor customers and transactions, and how to carry out the process of remote onboarding of customers.
The implementation of the system also included a series of training sessions for all client employees, which raised their awareness in AML/CFT. Selected employees were also trained in detail in the area of identifying money laundering risks in customer transactions.
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