ML/TPF and Sanctions Risk Advisory

List of Subjects of Law Obligated To Carry Out Client Due Diligence Is Long, and Almost All Fail To Properly Comply

For several years already the combating of money laundering and terrorism and proliferation financing is not done solely on the paper anymore. Legislator has engaged the society in fulfilling the important duty of helping to ensure public order in the country.

The Law on Money Laundering and Terrorism and Proliferation Financing Prevention specifies the groups of the society that have higher chance of involve or get involved in unlawful acts, even having no clue about it. These groups include such members of the economy as outsource accountants, tax consultants, real estate intermediaries, debt collectors, organisers of lotteries and gambling, sellers of art and antiques etc.

So what are those requirements binding for these subjects of the law? It is the duty to carry out client due diligence. A company must not only formally obtain the registration data of the partner, but must also take a closer and deeper look into their operation and transactions. This area is complicated and is causing headaches to very many companies. As the data on fined companies show, a large part of subjects of the law are failing to implement the requirements in their daily business and moreover are failing to comply even in the basic issues, not even mentioning the finer points. This is the time one should turn to a specialist in this area who will help to create or structure the normative documentation of the company, will provide support in carrying out client due diligence and will help in undergoing the inspections of the supervising institutions.

Our companies also are in the list of those subjects of the law, so we know the AML/CTPF issues in depth. We have gone through the inspections of the supervising authorities and have represented our clients in relations with them as well. Our lawyers and compliance specialists are experts in AML/CTPF requirements, client due diligence methods and peculiarities of applying of the law.

 

You will find our experience helpful to you as well!

 

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Laura Rudzate
Deputy Head of Department
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