Financial Crime World

Financial Institutions Must Be Vigilant Against Money Laundering and Terrorism Financing

Strengthening the Anti-Money Laundering and Counter-Terrorism Financing Regime

In an effort to prevent illegal activities, financial institutions and non-financial entities are being urged to regularly review their potential and existing risks of money laundering and terrorism financing. This is in accordance with Article 4 of the law, which requires these entities to identify and assess such risks prior to launching new products or business practices.

Identifying and Assessing Risks

  • Financial institutions and non-financial entities must identify and assess money laundering and terrorism financing risks when:
    • Launching new products or business practices
    • Using new or developing technologies
  • This is aimed at preventing the misuse of these systems for illegal activities

Reporting Suspicious Activities

  • Reporting entities are required to submit classified information to the authorized body, including information on suspicious transactions or business relationships
  • Reports must be filed by all reporting entities, regardless of the amounts involved, except in cases where the amount falls below a certain threshold
  • Specific types of transactions or business relationships are subject to mandatory reporting, including:
    • Non-cash transactions above AMD 20 million
    • Cash-related transactions above AMD 5 million
    • Real estate transactions above AMD 20 million (except for notaries)

Confidentiality Requirements

  • Authorities have emphasized the importance of confidentiality in reporting suspicious activities
  • Certain professionals are required to submit information only when doing so does not contradict their confidentiality requirements, including:
    • Notaries
    • Attorneys
    • Accountants
    • Auditing firms
    • Auditors

Proactive Approach

  • Financial institutions and non-financial entities are being urged to take a proactive approach in identifying and reporting suspicious activities
  • The law aims to strengthen the country’s anti-money laundering and counter-terrorism financing regime, and it is essential for these entities to be vigilant in preventing illegal activities.