About this service
The law on the prevention of money laundering and terrorism financing does not impose on accountable persons a separate formality but an entire institution: the compliance-control system, which begins with risk assessment, is fixed by an internal instruction and continues with reports on suspicious transactions. This service helps accountable persons build and audit precisely that system — so that from the first day the requirements work in practice, not on paper.
The compliance-control system and the internal instruction
Under Article 29 of the law, the accountable person must implement an internal-control policy, rules, systems and mechanisms proportionate to the nature and volume of its activity and the related risks. For implementation, an internal instruction is drawn up, approved by the governing body or a person with managerial authority. The instruction defines, among other things: the rights and duties of the head of the responsible person or unit and its staff; staff selection rules; a continuing-training programme; and an independent audit function to verify the system's effectiveness. The responsible person's position must correspond to the top hierarchical level, and responsibility for the system's effectiveness must lie with a member of the governing body or a person with managerial authority — compliance is thus not a second-rate administrative chore; it stands at the level of management.
Risk assessment and management
Article 8 establishes the intellectual core of the system: taking into account the nature and volume of its activity, the accountable person must implement an effective system of risk assessment and management and, with appropriate periodicity, assess and record the risks connected with its activity — based on the client and beneficial owner, their activity and jurisdiction, the product and the means of delivery. Before introducing a new technology, product or service, the risks are assessed in advance. The client's risk level is determined before an occasional transaction and before establishing a relationship, then periodically and on material change. In the assessment, account must be taken of the national risk assessment and the guidance of the Service and the supervisory organ — and on the supervisory organ's demand the accountable person must substantiate that the risks were properly assessed.