How Financial Market Participants Can Improve Their AML/CFT Compliance?

New instructions for financial market participants aimed at preventing money laundering and terrorist financing will come to an air from September 1, 2023.

Two mains outcomes market participants need to know:

  • A new requirement for market participants to inform the Bank of Lithuania on the appointed board member responsible for AML/CTF and MLRO is introduced.
  • Assessment on the internal control system’ effectiveness, efficiency and compliance to legal regulation, which is performed on the ongoing basis (daily by employees) and periodically at least every two years via #audit or other methods

The new BoL instructions provide that the assessment of the internal control should be documented and include:

  • The scope of the performed assessment
  • Customer testing scope and testing selection criteria
  • The period that was assessed
  • The assessment methodology, which would detail how the assessment of the selected area was carried out;
  • Policies and internal control procedures that were evaluated and their implementation in practice.
  • Regulatory ML/TF compliance testing of internal control systems, testing of efficiency and effectiveness, distinguishing specific assessed areas and providing an assessment of these specific assessed areas.

Do not forget to update your AML/CTF policies and procedures by including procedure for assessing and testing internal control system!

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