AML
Overview
Supervisors don't read your AML manual – they test whether you can prove it works. The gap between the two is usually wider than a firm expects.
We draft and review the AML/CTPF internal control documentation of obliged entities under the Latvian Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing: the business-wide risk assessment, the policies built on it, and the procedures that put them into practice.
What we advise on
Drafting and reviewing policies and procedures that reflect how the business actually operates, not a generic template carried over from elsewhere.
Drafting the business-wide and customer risk assessment methodology and the due diligence procedures built on it, including enhanced measures for higher-risk relationships.
Drafting internal procedures for sanctions screening of customers, counterparties and transactions, handling of matches, and steps to take when an existing relationship becomes subject to restrictive measures.
Preparing responses to supervisory requests and inspection findings.
Drafting the internal procedure from alert to decision, including escalation and reporting to the Financial Intelligence Unit.
Compliance framework
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Obliged entity
A person or entity subject to anti-money laundering and counter-terrorist and proliferation financing (AML/CTPF) obligations under Section 3 of Latvia's Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing. Obliged entities include credit and financial institutions, accountants, auditors, tax advisers, legal professionals providing certain services, corporate service providers, real estate intermediaries, gambling operators, debt recovery service providers, insolvency administrators, and other businesses and professionals engaged in activities specified by the Law.
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Beneficial owner
The natural person who ultimately owns or controls the customer, or on whose behalf a transaction is carried out. Identifying the beneficial owner is part of customer due diligence.
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Politically exposed person (PEP)
A natural person who holds or has held a prominent public function, such as a head of state or government, minister, member of parliament or judge of a supreme or constitutional court. Family members and close associates of a PEP are treated in the same way. Relationships with PEPs require enhanced due diligence.
Discuss your framework with our team.
Tell us where your framework stands and we will set out what a review would cover.