24/10/2019
ECOVIS ProventusLaw kicked-off its Knowledge Sharing Morning series by inviting it’s Fintech clients to an event dedicated to AML.
The aim of AML Knowledge Sharing Morning was to overview main changes that brings AMLD5 implemented in Lithuanian AML law, to share the Bank of Lithuania observations on what is expected from newcomers and Fintech startups. Moreover the Bank of Lithuania draft of financial market guidelines on ML/TF prevention was introduced and five AML Compliance program pillars were presented. The participants were explained how efficient KYC can help manage ML/ TF risks.
Main insights of the event:
– the Bank of Lithuania expects newcomers and Fintech startups to know their products and understand the associated risks, to have controls in place to mitigate ML/ TF risks, understand legal requirements and promote culture of compliance.
– AMLD5 will bring standardized enhanced customer due diligence requirements for payments involving high-risk third countries; expand list of a product, service, transaction or delivery channel risk factors as well as obliged entities.
– according to the new ML/ TF prevention guidelines, financial institutions will need to update their AML risk assessment at least once a year. The AML risk assessment will need to be based on data (client portfolio, products, etc.) or business plan. If any gaps are identified during AML risk assessment, remediation plan must be put in place and approved by management board or general manager.
– 5 pillars of AML Compliance program:
System of internal policies, procedures and controls;
Designated compliance function with compliance officer;
Training;
Independent Audit;
Customer Due Diligence
The event was conducted by Inga Karulaitytė, head of ECOVIS ProventusLaw Fintech group, and ECOVIS ProventusLaw AML team members, lawyers Alina Januškaitė and Eglė Gaigalaitė who focus on AML matters while Fintech is getting its license, assist with AML policies and procedures, AML expert Austėja Viederytė who focuses on AML risk assessment, audit, and consults how to begin operations in a compliant manner. A guest speaker Eimantas Vytuvis, CAMS, “Luminor” Head of Customer Data Quality Middle Office Lithuania, talked about efficient KYC and that this is the key element in AML/CTF program
If you need assistance to prepare your compliance program, draft relevant policies and procedures, perform independent AML Audit or Risk Assessment, review AML policies and procedures or complete thematic reviews, need introductory or specific training to all level of employees about AML, feel free to contact Ecovis ProventusLaw AML team.
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