Alexandre Pinot, CAMS

#MoneyLaundering and #TerroristFinancing - Current trends in the investigation of #CryptoAssets in France and Europe    On 6 November 2024 in Paris, France, the Council of Europe Economic Crime and Cooperation Division held the seminar “Crypto-assets and investigations into money laundering and terrorist financing (ML/TF): current trends in France and Europe”. The event is organised in cooperation with the Financial Intelligence Unit of France (Tracfin), the French Prudential Supervision and Resolution Authority and the European Commission’s DG REFORM.     The event is aimed at complementing the ongoing Tracfin efforts focused on developing a better understanding of the crypto phenomenon among its agents, thus enabling them to better detect and analyse potential scenarios of ML/TF misuse. Taking into consideration the scale of the ecosystem’s development and the range of underlying risks, Tracfin recognises the importance of effective cooperation with relevant stakeholders at both national and international levels.    In this regard, the seminar was convened to provide a platform for information-sharing and coordination between French competent authorities engaged in the regulation and supervision of crypto-asset service providers (#CASPs), as well as in the investigation of money laundering and terrorist financing cases involving crypto-assets.    💡 Deepen your knowledge on the issue here:  🔗 https://go.coe.int/3iYzf Financial Action Task Force (FATF) UNODC International Monetary Fund World Bank Development Economics INTERPOL EBRD OSCE

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#GoodToKnow Key AML & Sanctions Updates by the Bank of Lithuania The Bank of Lithuania has proposed amendments to key AML/CFT and sanctions resolutions, which will impact financial institutions and cryptocurrency service providers. 💡 What’s Inside? 🔹 Expanded AML measures for crypto providers. 🔹New 8-year sanctions documentation rule. 🔹Updates aligned with EU regulations. We’ve summarised draft resolutions by the BoL and provided actionable insights to help you stay compliant. Link in the comments 👇 #AMLCompliance #SanctionsUpdates #CryptoRegulation #FinancialMarkets #fintech #aml #sanctions #ecovis

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🇪🇺✨ EGBA welcomes the new EU anti-money laundering package which was finalised yesterday, following approval by the Council of the European Union. The new rules will benefit online gambling operators by standardising AML rules and reporting requirements. Obliged entities will have 3 years to comply with the new rules. The final legislative package provides for: 🏢 The establishment of the European Anti-Money Laundering Authority (AMLA) – based in Frankfurt, AML will have direct and indirect supervisory powers to ensure compliance with AML requirements, working in tandem with national AML authorities. AMLA will be responsible for a large amount of technical and implementing rules that will directly apply to the online gambling sector. 📖 The 6th Anti-Money Laundering Directive – containing national provisions on supervision and the powers of national AML authorities, including their access to requisite and reliable information such as beneficial ownership registers. 🔍 A new Anti-Money Laundering Regulation (AMLR) – encompasses requirements for conducting due diligence, transparency of beneficial owners and much more, directing practitioners through the whole AML process for obliged entities. The regulation sets a limit of €2000 for conducting due diligence on players for online gambling operators. 📅 The new AMLR will enter into force three years after its publication in the Official Journal of the EU, which is the next step in the process. 💡 To support compliance efforts, EGBA has developed industry-specific guidelines. Operators can prepare for the EU's AML rule changes and contribute to the fight against money laundering in the EU by signing up. Learn more about the guidelines here: https://lnkd.in/gEHGDHF3 💬 "We welcome the finalisation of the new anti-money laundering package. EGBA has actively followed and contributed to the revision of the AML rules at EU-level and believes the new rules will benefit Europe’s online gambling operators, especially those operating in multiple jurisdictions, by ensuring a single regulatory approach across EU member states. With finalisation of the new rules, EGBA will review and update its industry guidelines on AML to ensure their alignment with the rules. By signing up to the guidelines, operators can begin preparing themselves for the EU rule changes and join our members in their efforts to proactively and positively contribute to the fight against money laundering in the EU." – Dr. Ekaterina Hartmann, Director of Legal and Regulatory Affairs, EGBA. 🔗 Read our press release here: https://lnkd.in/e5csGSYe 🤝 If you are an EU-based online gambling operator and are interested to participate to EGBA’s industry guidelines on AML, please contact us. #AML #EU #CFT #CDD #antimoneylaundering #iGaming #Gambling

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𝐄𝐁𝐀 𝐏𝐫𝐨𝐩𝐨𝐬𝐞𝐬 𝐀𝐌𝐋 𝐑𝐮𝐥𝐞𝐬 𝐟𝐨𝐫 𝐂𝐀𝐒𝐏𝐬 The European Banking Authority (EBA) has launched a public consultation on new Regulatory Technical Standards (#RTS) focused on anti-money laundering (#AML) compliance for crypto-asset service providers (#CASPs). These proposals aim to address vulnerabilities in the crypto sector by requiring CASPs to appoint central contact points (#CCPs) in host member states. CCPs will ensure adherence to local AML/CFT regulations, acting as liaisons with national authorities. Read more here: https://lnkd.in/dhCWGVgR #GTG #CryptoCompliance #CryptoRegulation #EBA #RegTech Cherise Abela Grech l Catriona Cuschieri

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🏦 The Bank of Lithuania has announced its 2025 inspection plan. Scheduled inspections: 🔹 5 electronic money and payment institutions 🔹 2 insurance companies 🔹 3 banks 🔹 1 credit union. The goal of these inspections is to ensure that financial market participants comply with legal requirements, transparency, and reliability standards. 🔍 The inspections will assess: ✔️ AML/CTF compliance ✔️ Prudential and operational management requirements ✔️ Internal control mechanisms and other key aspects This will help the Bank of Lithuania ensure that financial market participants operate responsibly and reliably, thereby protecting consumer interests and strengthening trust in the financial system. 💼 If your company is on the inspection list or you want to prepare in advance, we at ExpertLab can help you get ready for the inspection process. 📧 Contact us! More information – link in the comments.

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How is the GIIF's on-site control of AML/CTF institution carried out? 🔍 The General Inspector of Financial Information (GIIF) plays a crucial role in ensuring compliance with anti-money laundering and counter-terrorist financing (AML/CTF) regulations in Poland. The GIIF conducts controls of institutions obligated to implement AML/CTF measures, mainly under the Polish AML Act. The process of control follows a procedure which consists of several stages: Preparation Stage 📋 • The GIIF initiates the control process by selecting the institution to be controlled based on risk analysis and other relevant factors. • An controllers team is appointed, and a notification letter is sent to the controlled institution, informing of the upcoming control. Preliminary Stage 📑 • The controllers team conducts a preliminary analysis of the institution's documentation, including internal AML/CTF procedures, risk assessments, and transaction records. This stage helps the controllers understand the institution's operations and identify potential areas of concern. On-Site Inspection 🏢 • The controllers conduct an on-site inspection at the institution's premises. During this stage, they review documentation, observe processes, and interview relevant personnel to assess the effectiveness of the institution's AML/CTF measures. • Controllers may also request additional information or documentation as needed. Post-Inspection Stage 📝 • After the on-site inspection, the controllers team analyzes the collected data and prepares a draft control report. The draft report is shared with the controlled institution, allowing to provide explanations or clarifications. Final Report and Recommendations 📄 • Based on the institution's response and any additional information provided, GIIF finalizes the control report. The report outlines the control findings, identifies any deficiencies or non-compliance issues, and provides recommendations for improvement. • If significant violations are found, GIIF may impose administrative sanctions or refer the case to law enforcement authorities. Follow-Up and Monitoring 🔄 • GIIF monitors the implementation of the recommendations provided in the control report. The controlled institution is required to take corrective actions and provide periodic updates on their progress. • GIIF may conduct follow-up controls to verify the effectiveness of the implemented measures. Throughout the process of control, GIIF shall adhere to principles of transparency, objectivity, and confidentiality. The control’s aim is to identify potential risks, assess the adequacy of AML/CTF measures and ensure that institutions comply with relevant laws and regulations. 🛡️

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📢 📝 August 16, 2024. The Bank of Lithuania outlined detailed requirements for the management body members of crypto-asset service providers (CASPs), based on Articles 62, 68, and 69 of the MiCA regulation.   🔍 Key Takeaways: ▶️ Members of the management body (Members) must have a good reputation, sufficient knowledge, and experience to fulfil their duties effectively. This includes demonstrating their ability to dedicate enough time to their responsibilities. ▶️ Members must provide evidence of a clean criminal record from relevant commercial, insolvency, financial, anti-money laundering, and fraud-related laws. ▶️ The evaluation of their qualifications considers education, work experience, and other factors affecting their competence, in line with ESMA and EBA guidelines. ▶️ CASPs must ensure independence in governance by appointing non-executive members, avoiding undue influence, and fostering objective decision-making. ▶️ Management must demonstrate proper governance structures with clear procedures and controls to avoid conflicts of interest in decision-making. ▶️ Lithuanian residency for key decision-makers is advised to ensure effective oversight and governance. ▶️ Any changes in the management body must be reported to the Bank of Lithuania and approved before the new members assume their roles.   🤷‍♂️ The So What? ✅ CASPs should aim to adhere to the regulatory requirements to ensure compliance and smoothen licensing process under MiCA regulation.   📩 Do you have any questions? Feel free to reach out via DMs!:) #AdamanoConsulting   #MiCA | #CryptoRegulation | #Governance 

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US FinCen updates Beneficial Ownership Information FAQs. FinCen has updated its FAQs on Beneficial Ownership Information, amending 2 FAQs and issuing 2 new ones: FAQ C. 14, which provides that a company is still required to submit its initial report to FinCen even if it is ceases to exist before the report is due, has been updated; FAQ C. 15 has been added, addressing who may submit a report on behalf of a reporting company that no longer exists; FAQ C. 16 has been added, clarifying that a foreign company that stopped doing business in the US before reporting requirements came into effect (1 January 2024) does not need to file a report; and FAQ G. 4, which details when a reporting company needs to include historical beneficial owners in its report, has been updated. #Sanctions #Russia #EUCommission #ExportControl #TradeWar #TSECS #SanctionsUpdate #TurkishSociety #Sanctions #USA #OFAC #BIS #TradeUpdates #GlobalTrade #TradeCompliance #InternationalRelations #EconomicSanctions #TradeRegulations #TurkishExports #TradePolicy #SecurityMatters #ForeignPolicy #ComplianceNews #EconomicSecurity #CrossBorderBusiness

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The full texts of the new EU AML package have now been published. This is a leading case: we can learn from this approach on data sharing among states, and registers are being interconnected using a similar standard. This week #IACC2024 convenes a wide community of experts working on these issues. One clear theme has been an affirmation of how useful is #BeneficialOwnership #transparency is as a tool not only for #AML, but also to help address other pressing challenges such as #corruption, climate financing and international taxation. We recently wrote about the EU AML package: https://lnkd.in/e9SQnwg7

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Many businesses check off AML compliance boxes but often skip a crucial step: name checking against global watchlists. Missing this could mean unknowingly dealing with sanctioned parties or bad actors. Protect your business with digital tools that make name screening simple, quick, and affordable. Read our latest article to learn more 🔍✅ #AMLCompliance #NameCheck https://lnkd.in/gAgRXzAw

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Regulation (EU) 2015/847, implemented in 2015, aligns with FATF’s Recommendation 16, mandating that payment service providers (PSPs) ensure funds transfers include specific payer and payee information - the “travel rule.” This measure aims to curb financial crime, particularly terrorism financing, by enabling authorities to 'detect the transfer of funds lacking this information, and to determine whether to execute, reject or suspend such transfers'. Following FATF's 2019 extension of Recommendation 16 to virtual asset service providers, the EU further updated its legislation with Regulation (EU) 2023/1113, extending AML/CFT requirements to crypto-asset service providers (CASPs). This update requires CASPs to uphold AML/CFT standards equivalent to those for other financial institutions. Related link: Travel Rule Guidelines - https://lnkd.in/eUkmzgQT

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#MoneyLaundering and #TerroristFinancing - Current trends in the investigation of #CryptoAssets in France and Europe On 6 November 2024 in Paris, France, the Council of Europe Economic Crime and Cooperation Division is holding the seminar “Crypto-assets and investigations into money laundering and terrorist financing (M/TF): current trends in France and Europe”. The event is organised in cooperation with the Financial Intelligence Unit of France (Tracfin), the French Prudential Supervision and Resolution Authority and the European Commission’s DG REFORM. The event is aimed at complementing the ongoing Tracfin efforts focused on developing a better understanding of the crypto phenomenon among its agents, thus enabling them to better detect and analyse potential scenarios of ML/TF misuse. Taking into consideration the scale of the ecosystem’s development and the range of underlying risks, Tracfin recognises the importance of effective cooperation with relevant stakeholders at both national and international levels. In this regard, the seminar was convened to provide a platform for information-sharing and coordination between French competent authorities engaged in the regulation and supervision of crypto-asset service providers (#CASPs), as well as in the investigation of money laundering and terrorist financing cases involving crypto-assets. 💡 Deepen your knowledge on the issue here: 🔗 https://go.coe.int/3iYzf

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The EU is taking bold steps against financial crime with the establishment of a new Anti-Money Laundering Authority and strict regulations to bolster Europe’s defenses. From enhanced customer due diligence to transparency in beneficial ownership, these measures promise to reshape the financial landscape. Read more about the EU’s AML/CFT package here and understand why it matters: https://buff.ly/3KXNe1Z #AML #FinancialRegulation #MoneyLaundering

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📢 𝗘𝘀𝘁𝗮𝗯𝗹𝗶𝘀𝗵𝗶𝗻𝗴 𝗮 𝗦𝘂𝗰𝗰𝗲𝘀𝘀𝗳𝘂𝗹 𝗘𝗨 𝗔𝗠𝗟𝗔 – 𝗸𝗲𝘆 𝗶𝗻𝘀𝗶𝗴𝗵𝘁𝘀! Prominent EU AML/CTF experts share their perspectives on the establishment of a successful EU AMLA. Gediminas Šimkus, Governor, Bank of Lithuania “It is of utmost importance for AMLA to have a good overview and knowledge of the EU Member States‘ markets, as well as to promote the convergence of supervisory practices. Therefore, at least one entity per Member State should fall under direct AMLA supervision.   Extensive information exchange and deep cooperation are central for the EU AML/CFT framework.” Marcus Pleyer, German Ministry of Finance & former FATF President ‘’What is still missing, however, are measures that enable authorities to take EU-wide action at the same pace and within the same mindset as transnational money launderers. Only by doing so can we prevent criminals from exploiting the freedoms of the single market by taking the path of least resistance for their ML activities.   We should not let the opportunity pass us by to build up the AMLA from scratch and install custom-made decision making processes.’’ 𝗣𝗵𝗶𝗹𝗶𝗽𝗽𝗲 𝗕𝗲𝗿𝘁𝗵𝗼, Director AML/CFT, ACPR “For groups of obliged entities with significant cross border activity, both within the EU and in non-EU territories, comprehensive risk-based requirements at groups’ level would address ML/TF cross border and trans-sectoral nature. AMLA’s direct supervision scope needs to be crafted so that it adds value to the existing framework.’’ Jesper Berg, Director, Danish Financial Supervisory Authority “Both authorities and the private sector play a crucial role in fighting ML/TF. Increased cooperation, exchange of information and usage of technology must necessarily go hand in hand with making our common efforts more efficient. Technology and Public Private Partnership is the Greenfield Opportunity for AMLA’’   Derville Rowland, Financial Conduct Director , Central Bank of Ireland   ''AMLA must also embrace an intelligence-led approach to its direct supervision ensuring that its resources are concentrated on the areas of greatest risk. Information sharing with ESMA, the ECB, NCAs and FIUs will be essential to this intelligence led approach.   Enhanced convergence, co-ordination and cooperation between the broad coalition of actors is vital.”   Duncan DeVille, former Global Head of FCC, Western Union “A further improvement would be to require the new AMLA and the national FIUs to swiftly agree on common suspicious transaction report templates. This would streamline the reporting process and allow for the use of modern analytical tools to report suspicious transactions.   We believe individual companies should have the right to opt in to the sole and direct supervision by the AMLA.” Feel free to share your thoughts on these proposed expert perspectives! Stay tuned!

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N26 fined €9.2 million by BaFin for AML failures, but customer onboarding cap lift possible this year German regulator BaFin has fined N26 €9.2 million for AML failures. The penalty comes after BaFin concluded that N26 systematically submitted suspected money laundering reports late in 2022. This is the latest development in a series of regulatory actions against N26 concerning its AML controls. In 2021, BaFin fined the bank €4.25 million and imposed a cap on new customer onboarding. The cap, currently set at 50,000 new customers per month, remains in place alongside an ongoing audit presence. While BaFin extended the cap in July 2023 due to persisting deficiencies, Bloomberg reports that the regulator might lift it as early as this year. N26 claims to have implemented significant improvements to its reporting processes and invested heavily in personnel and infrastructure to combat financial crime. #N26 #AML #Fintech #Regulation #FinancialCrime #NeurobayStrategy #NeurobayCompliance #BaFin

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🇨🇿 Understanding ultimate beneficial owners is crucial in the fight against money laundering and terrorism financing in the Czech Republic. Identifying ultimate beneficial owners strengthens transparency, exposes hidden or unclear structures and is often essential in processes like public procurements, grants, and licenses. Download our free eBook to learn more about ultimate beneficial owner regulations and their importance 👇 https://lnkd.in/eXZBWWi3

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🇩🇪 The German Federal Financial Supervisory Authority #BaFin and Financial Intelligence Unit #FIU released an orientation guide on submitting suspicious transaction reports #STRs. The document is aimed at providing further clarification on the terms “immediateness” and “completeness” when submitting reports. Key takeaways include:  ➡️ If facts exist that point to circumstances outlined in the Money Laundering Act #GWG, reports should be made on the same or following working day; ➡️ Emphasising the importance of submitting data in the structured formats either through the reporting form or in the XML schema of GoAML; and ➡️ Stressing that reports must be complete containing relevant information on persons, organisations, accounts, and transactions. ✅ Firms with operations in Germany should review the guide to further understand regulatory expectations when submitting suspicious transaction reports. Learn more: https://lnkd.in/e7ahpvkD

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🇪🇺 EBA News: Strengthening AML/CFT Compliance for Crypto-Asset Service Providers Today, the European Banking Authority (EBA) launched a public consultation on the criteria for appointing a Central Contact Point (CCP) for #cryptoassetserviceproviders (#CASPs). This initiative aims to ensure #compliance with #antimoneylaundering (#AML) and countering the #financingofterrorism (#CFT) regulations in host Member States. Why does this matter? As CASPs operate across borders through entities other than branches, ensuring effective AML/CFT supervision becomes increasingly complex. The proposed Regulatory Technical Standards (RTS) define when a CCP is needed and outline its key functions to enhance oversight. Key dates to remember: Deadline for comments: 4 February 2025 Virtual public hearing: 16 January 2024 This proposal updates Regulation (EU) 2023/1113, extending AML/CFT requirements to CASPs, while following the framework already in place for electronic money institutions (EMIs) and payment service providers (PSPs). How to get involved: Submit your feedback via the #EBA consultation page and register for the public hearing by 3 January 2024.

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