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Obliged Entities Must Conduct CDD Procedures When Doubt Arises

The Financial Intelligence Unit has identified several deficiencies in the country’s anti-money laundering and combating the financing of terrorism (AML/CFT) regime. However, significant progress has been made since the evaluation.

Improving Customer Due Diligence

One key improvement is the requirement for obliged entities to conduct customer due diligence (CDD) procedures when there is doubt about the veracity or adequacy of previously obtained client identification data. This is in line with Article 8-d of the AML/CFT Act, which stipulates that obliged entities must apply CDD procedures in such cases.

• Obliged entities must conduct CDD procedures when there is doubt about the veracity or adequacy of previously obtained client identification data.
• The authorities have addressed other deficiencies identified in the previous evaluation.

Strengthening Record-Keeping Requirements

The AML/CFT Act has also improved record-keeping requirements, which were previously criticized as being too short-term and inadequate. Obliged entities are now required to keep all necessary records on transactions for at least 10 years from the transaction date, and to keep identification data for at least 10 years from the end of the business relationship.

• Record-keeping requirements have been improved.
• Obliged entities must keep records on transactions for at least 10 years from the transaction date.
• Identification data must be kept for at least 10 years from the end of the business relationship.

Enhancing Suspicious Transaction Reporting

The AML/CFT Act has also improved suspicious transaction reporting (STR) requirements, which previously did not explicitly cover attempted transactions. The amended law now requires obliged entities to report attempted transactions, and Article 29 of the act provides for the requirement for other financial institutions apart from banks to submit STRs.

• Suspicious transaction reporting requirements have been improved.
• Obliged entities must report attempted transactions.
• Other financial institutions are required to submit STRs, in addition to banks.

Conclusion

While there are still some areas that require improvement, significant progress has been made in strengthening the country’s AML/CFT regime. The authorities have addressed deficiencies and improved procedures for CDD, record-keeping, and suspicious transaction reporting.