AML/CFT development since introduction of the 3rd EU AML
Directive
5-6 of November, 2009Tallinn
Regulatory AML/CFT framework
Law of the Republic of Lithuania on the Prevention of
Money Laundering and Terrorist Financing
Resolutions of the Government of the Republic of Lithuania
Other legal acts (e.g. Law on Commercial Banks of Lithuania)
Group AML/CFT requirements
Controlling institutions
The Bank of Lithuania
The Financial Crime Investigation Service (aka FIU)
The Securities Commission of the Republic of Lithuania
Insurance Supervisory Commission of the Republic of
Lithuania
What are key AML/CFT requirements?
Identification of
beneficial owner
Politically
Exposed
Person?
Customer risk scoring
Monitoringofcash operations
Screening against sanction lists
Keeping the Register on transactions and regularly
submitting it to FIU
Reporting SAR/STR to FIU
Regular AML/CFT
training for staff
Brief overview of AML/CFT efforts
KYC due diligence (Beneficial Owner, PEP)
High risk customers’ adoption committee
New Products’ Approval Committee
Screening against designated sanction lists
Automated monitoring of financial transactions in order
to identify suspicious activities
Class room/e-training for staff
Main AML/CFT challenges
Staff’s reluctanceto ask inconvenient questions
Dissatisfied and irate
customers
Identification of beneficial
owners
Due diligence of foreign nationals
Feedback from FIU
Intricacies of automated monitoring systems
Exchange of information about blacklisted customers
Thank you for your attention!