Povilas Randis CAMS, PMP, ICA Dip(AML), CFE, CIPP-E, LL.M.

🔵 Office for Money Laundering Prevention of the Republic of Slovenia updates the list of countries at risk of money laundering or terrorist financing 👉🏻 The Office has updated the list of countries with weak or incomplete implementation of legislation, which can be associated with risks that may affect the effectiveness of the fight against money laundering and terrorist financing. The list includes countries with strategic deficiencies in anti-money laundering or counter-terrorism financing measures, countries with inadequate tax legislation, those known for drug production, and countries that host individuals subject to restrictive measures related to money laundering, terrorism financing, and terrorism, as reported by the office. 👉🏻 For example, Antigua and Barbuda have been removed from the EU’s list of non-cooperative jurisdictions for tax purposes, thereby fully removing them from the high-risk countries list. Additionally, Lebanon, Syria, and Thailand have been added to the list of countries that produce raw materials for illicit drug production, with Thailand as a new addition to the combined high-risk countries list. 🔗 See the list here: https://lnkd.in/enZt_i32 (in Slovenian) #IraMašič #Attorney #Law #LegalNews 

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📢📝 April 11, 2024. #AML and #redflags. Lithuania’s Financial Crime Investigation Service (“FIU”) updated the list of possible criteria for identifying money laundering and suspicious monetary transactions or transactions (“List”). The List will enter into force in May 1, 2024. Key takeaways on the List: ▶️ The List covers suspicious criteria on customer behavior, transactions, geographies, acts of corruption. ▶️ Although the List was updated, the criteria remain usual for monitoring practices, hence financial institutions should be familiar with criteria. ▶️ The List is not exhaustive, hence, financial institutions should align the criteria to the business model.    🤷‍♂️ The So What? The financial institutions should: ✅ Review the List to identify the any missing criteria. ✅ Update internal monitoring criteria against the List to ensure compliance (for Lithuania-licensed financial institutions). ✅ Test the monitoring system with updated criteria and calibrate, if needed. 📩 Do you have any questions? Feel free to ask in DMs :) #AdamanoConsulting #AML | #moneylaundering | #financialcrime | #FIU

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🚨 New FNNT Rules for Virtual Currency Operators in Lithuania 🚨 The Financial Crime Investigation Service (FNNT) in Lithuania has issued new guidelines for virtual currency operators, explaining the necessary documents to prove that companies have at least €125,000 in capital, as now required by law. 📌 What You Need to Provide: You may need to submit financial reports for the first half of 2024, which have already been sent to the Register of Legal Entities. Additionally, a general ledger from your company’s financial system, dated June 30, 2024, or later, might be required. By August 31, 2024, you must provide confirmation of your registered capital, demonstrate the availability of funds on your company’s balance sheet, and prepare a policy to ensure compliance with capital requirements. Depending on your specific case, additional documents may also be needed. A cash report covering June-July 2024, along with a bank statement showing a balance of at least €125,000 as of August 1, 2024, should also be included. Furthermore, an insurance policy or financial guarantee may be necessary to demonstrate financial backing. It’s important to remember that providing just a bank statement or a certificate confirming €125,000 in share capital won’t be sufficient. Depending on your specific case, a combination of these documents might be needed, and sometimes additional documentation as well. 💼 Why This Matters: These new rules ensure that virtual currency businesses in Lithuania maintain financial stability and operate transparently. While these requirements might seem challenging, they are essential for maintaining a secure and fair market. Failure to comply could result in significant penalties and operational disruptions. At Legalaes, we’re here to help you navigate these new regulations. Our expert team can guide you through the process, ensuring your business remains compliant and continues to thrive. Don’t let these new requirements slow you down—contact us today to protect your business. #LithuaniaCrypto #CryptoRegulations #Compliance #VirtualCurrency #FNNT #Legalaes

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Understanding and managing financial crime risks is crucial for organisations amidst evolving criminal practices. Explore the main pillars of sound financial crime compliance in Jonathan Camilleri's latest article. #FinancialCrimeCompliance #RiskManagement #GRCinMalta

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US FinCen updates Beneficial Ownership Information FAQs. FinCen has updated its FAQs on Beneficial Ownership Information, amending 2 FAQs and issuing 2 new ones: FAQ C. 14, which provides that a company is still required to submit its initial report to FinCen even if it is ceases to exist before the report is due, has been updated; FAQ C. 15 has been added, addressing who may submit a report on behalf of a reporting company that no longer exists; FAQ C. 16 has been added, clarifying that a foreign company that stopped doing business in the US before reporting requirements came into effect (1 January 2024) does not need to file a report; and FAQ G. 4, which details when a reporting company needs to include historical beneficial owners in its report, has been updated. #Sanctions #Russia #EUCommission #ExportControl #TradeWar #TSECS #SanctionsUpdate #TurkishSociety #Sanctions #USA #OFAC #BIS #TradeUpdates #GlobalTrade #TradeCompliance #InternationalRelations #EconomicSanctions #TradeRegulations #TurkishExports #TradePolicy #SecurityMatters #ForeignPolicy #ComplianceNews #EconomicSecurity #CrossBorderBusiness

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Interesting perspectives on the future role of the EU AMLA and how it must contribute to increasing the effectiveness of the EU AML control framework. The bar is high, as are the risks at stake. Curious to see whether all member states will have the political willingness and courage to live up by those standards. If the AMLA taken in isolation is not the only answer, it is however a key tool for the EU to clean its economy from illicit money. Now, we all know it is a global answer to this global issue that is needed, and the FATF certainly contributes to this objective, but let’s take it one step at a time. Thanks J. Adriana Juric, AMLP Forum AMLP Forum for the original post. #aml #financialcrimecompliance #fcc

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➡ Feel free to visit my new podcast dedicated to the EU AML Package and Financial Crime in general. I am going to add new content on regular basis. ✔ So fat there are two episodes: 1️⃣ Unboxing of the AML PAckage and brief overview of its contents, 2️⃣ EU AML Regulation - the common rulebook for obliged institutions. ✅ The latter to be followed up with elaborated content and comments. Happy Halloween! #AML_package #EU_AML_Regulation #AML_common_rulebook

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How is the GIIF's on-site control of AML/CTF institution carried out? 🔍 The General Inspector of Financial Information (GIIF) plays a crucial role in ensuring compliance with anti-money laundering and counter-terrorist financing (AML/CTF) regulations in Poland. The GIIF conducts controls of institutions obligated to implement AML/CTF measures, mainly under the Polish AML Act. The process of control follows a procedure which consists of several stages: Preparation Stage 📋 • The GIIF initiates the control process by selecting the institution to be controlled based on risk analysis and other relevant factors. • An controllers team is appointed, and a notification letter is sent to the controlled institution, informing of the upcoming control. Preliminary Stage 📑 • The controllers team conducts a preliminary analysis of the institution's documentation, including internal AML/CTF procedures, risk assessments, and transaction records. This stage helps the controllers understand the institution's operations and identify potential areas of concern. On-Site Inspection 🏢 • The controllers conduct an on-site inspection at the institution's premises. During this stage, they review documentation, observe processes, and interview relevant personnel to assess the effectiveness of the institution's AML/CTF measures. • Controllers may also request additional information or documentation as needed. Post-Inspection Stage 📝 • After the on-site inspection, the controllers team analyzes the collected data and prepares a draft control report. The draft report is shared with the controlled institution, allowing to provide explanations or clarifications. Final Report and Recommendations 📄 • Based on the institution's response and any additional information provided, GIIF finalizes the control report. The report outlines the control findings, identifies any deficiencies or non-compliance issues, and provides recommendations for improvement. • If significant violations are found, GIIF may impose administrative sanctions or refer the case to law enforcement authorities. Follow-Up and Monitoring 🔄 • GIIF monitors the implementation of the recommendations provided in the control report. The controlled institution is required to take corrective actions and provide periodic updates on their progress. • GIIF may conduct follow-up controls to verify the effectiveness of the implemented measures. Throughout the process of control, GIIF shall adhere to principles of transparency, objectivity, and confidentiality. The control’s aim is to identify potential risks, assess the adequacy of AML/CTF measures and ensure that institutions comply with relevant laws and regulations. 🛡️

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🔔 Attention VASPs in the Czech Republic: New AML Law Amendments Effective As of May 1, 2024, the Czech AML Law (Act No. 253/2008 Coll.) has been amended, impacting all VASPs under the Financial Analytical Office (FAU) supervision. https://lnkd.in/gar4fh6i Mihhail Šerle, Senior Partner at Gofaizen & Sherle, provides an accessible overview of these pivotal changes. Stricter Identification Requirements VASPs must now gather additional details, including the ID card number, issuing authority, and expiration date. The "country of origin" definition has expanded beyond the previous "country of establishment," affecting: Natural Persons: States of nationality, residence registration, or residence exceeding one year. Legal Entities: States of registered office or business operations. An exception permits VASPs to forego client identification during FAU investigations. Remote Identification Flexibility VASPs can now use the test payment method for identification, accepting payments from all countries except high-risk third countries. This marks a departure from the previous EEA-only account requirement. Internal Policy Provisions VASPs must submit their AML-compliant internal policies to the FAU within 60 days of establishment and report any policy changes within 30 days. Policies must be in Czech or Slovak, as per FAU guidelines. Existing VASPs have until May 31, 2025, to comply. Non-compliance could result in fines up to CZK 1,000,000 (~€40,000). For more information, please do not hesitate to contact us via email at [email protected] To stay updated, subscribe to our Telegram channel https://lnkd.in/gu4Zukrw

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📣 Unable to attend the Fight FinCrime Forum at Warsaw Finance Week in person? No worries - you can join us online!   🗓️ Date: 20.11.2024 🕓 Time: 1 pm-5 pm ➡️ Registration: https://lnkd.in/dWpsXxhH   Fight FinCrime Forum is an annual event that aims to connect AML and financial crime prevention professionals so they can build networks and synergy, to provide an opportunity for exchange of experiences and to share the knowledge and best practices.   This year’s edition will be part of the Warsaw Finance Week and will take place on November 20th, at the Warsaw Stock Exchange The Forum is designed for regulated financial institutions and FinCrime prevention professionals, representatives of regulatory authorities, industry associations, fintech companies, and everyone interested in the AML agenda. This year, the focus will be on EU AML packages, which are crucial to the transformation and continued advancement of the anti-money laundering efforts. Our goal is to identify challenges, good practices and new opportunities for synergy between obligated institutions, regulators and service providers present on the Polish market, positioning Warsaw as a modern financial hub.   PwC, Salv, ACAMS, EY Pawel Widawski, Piotr Brewiński, Gabriela Mrozek, Kasia Jedlińska, Katarzyna Multan, Aneta Girdwoyń (Kmoch), Zuzanna Krauzowicz, Anna Malanowska   #FightFinCrimeForum #WarsawFinanceWeek #FinTechPoland

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Stay updated on the latest regulatory developments in Malta and the EU with KPMG's Forensic AML/CFT Regulatory Radar. This comprehensive guide to the AML/CFT regulatory framework offers an overview of the most recent advancements in this field. 🔎 👉 Learn more and download the publication through the link below. For further discussions, please reach out to Alex Azzopardi, Giselle Borg, or Deborah Cassar. #kpmg #riskconsulting #aml #cft #regulatoryframework

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🔎Registering for the Polish Central Register of Beneficial Owners (CRBR) can be tricky, and many companies make common mistakes (that may cost them money - an incorrect entry in the register or lack of it may result in a fine of up to PLN 1,000,000!). Here are the top 3 errors to avoid: 🚫Non-compliance with Representation Rules Just as with signing contracts and legal documents, only authorized individuals can sign CRBR submissions. For example, in a limited liability company (sp. z o.o.) that requires joint representation by 2 board members, two signatures will be necessary for the registration. 🚫Submitting Notification via Proxy The Ministry of Finance's Q&A clearly states that filings cannot be made through a proxy. Although the system allows for the option "submitter - other," this is not intended for submissions by proxy. To ensure compliance, we typically prepare a correct file for our clients, which they can upload and sign independently. 🚫Incorrect Beneficiary Data Last common error is failing to list the actual representative (e.g., the CEO) as a beneficial owner, even though they often hold this role. It’s crucial to enter their details in both sections of the registration. Additionally, all rights of the beneficial owner must be listed—if the owner has both direct and indirect ownership rights (e.g., through a parent company), both should be included. ✅Avoiding these mistakes ensures your CRBR submission is compliant and accurate. Adwisen offers you professional guidance - don’t hesitate to contact us! #CRBR #Compliance #PolishBusiness #RiskManagement #Adwisen

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Do you know? When reporting a sanction hit to The Sanctions Monitoring Board - Malta, the following standard template must be used 👉 https://lnkd.in/drVh7kpH The same was published yesterday along with other important points on reporting obligations under the National Interest (Enabling Powers) Act (Chapter 365 of the Laws of Malta) 👉 https://lnkd.in/dpFYtFSW #Sanctions #SanctionsCompliance #Malta #SMB #FinancialCrimeCompliance #RegulatoryReporting

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