Scope of Obligations And Client Due Diligence

As a legal service provider, this practice is classified as an “obliged entity”, requiring adherence to the national Measures Against Money Laundering Act (MAMLA) and harmonized AML/CTF standards across all EU Member States. This includes enhanced due diligence, beneficial ownership transparency, and suspicious transaction reporting.

We perform thorough risk-based assessments of our clients, verifying identity, beneficial ownership, and the nature and purpose of the business relationship., including verification of identity, beneficial ownership, and the purpose of engagement. For high-risk clients (e.g., politically exposed persons or entities in high-risk jurisdictions), additional documentation and ongoing monitoring are required.

We comply with EU-wide transparency requirements, ensuring accurate disclosure of beneficial owners for legal entities and trusts. Non-EU entities with real estate holdings, public procurement contracts, or business relationships with EU-based obliged entities are subject to equivalent reporting requirements.

Suspicious Activity Reporting

If we suspect a transaction might involve illegal funds or support terrorism, we are legally obligated to report it to the Financial Intelligence Directorate of the State Agency for National Security (FID-SANS). This duty overrides client confidentiality in such cases. We are prohibited from informing clients if a report has been filed, in compliance with anti-tipping-off laws.

Record Keeping

We securely store records of client interactions, transactions, and due diligence checks for 5 years after our engagement ends. These records help authorities investigate potential crimes.

Internal Safeguards

Our team undergoes regular training to spot risks and follows strict policies to prevent misuse of our services. A dedicated compliance officer ensures we meet legal standards.

Client Responsibilities

We ask clients to provide accurate information promptly and notify us of any changes in their circumstances. Delays or incomplete details may slow our work or lead to or engagement termination.

Third-Party Relationships

Subcontractors and external service providers are vetted for AML compliance, with contractual safeguards to ensure adherence to national and EU standards. Cross-border data transfers involving non-EU entities rely on adequacy decisions or Standard Contractual Clauses.

Updates and Enforcement

Any updates to this policy resulting from changes in EU regulations or national implementing laws will be communicated promptly.