Implementation of AML (Anti-Money Laundering) procedure
We recently carried out a project to implement aml and terrorist financing procedures for an accounting institution providing services to group companies.
The need to implement AML procedures at our client was due to the amendment of the AML/CFT Act, which expanded the catalogue of entities defined as an obliged institution.
Our tasks included the creation of an internal AML procedure, covering comprehensive regulation of the issues of customer identification (KYC), identification and verification of the beneficial owner, risk analysis and establishment of financial security measures, which were important for the Company.
The atypicality of the project consisted in the development of documentation for an entity that does not carry out transactions within the meaning of the AML and Terrorist Financing Act, as well as the development of detailed rules for periodic monitoring of clients and typing of unusual, undesirable behaviour.
In addition, we developed a procedure for anonymous reporting of actual or potential AML violations and a scheme of action in the event of suspicious activity of our client’s counterparties. The entire procedure created was completed by training of the client’s employees by our law firm in AML.
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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).
As part of our ongoing cooperation with a client, a small payment institution, providing payment services including issuing of credit cards and providing payment credit to consumers, we represent the client in the proceedings for obtaining a license to provide payment services as a national payment institution.