A clear internal AML policy helps the organization comply with the law, reduce the risks of fraud and money laundering, and protect the company’s reputation. It establishes standard procedures for client identification, transaction monitoring, and reporting of suspicious activities, ensuring a coherent and effective framework for preventing money laundering.

The AML program is a set of policies, procedures, and internal controls designed to prevent and combat money laundering and terrorist financing. In Romania, the obligation to implement it applies to all reporting entities, including financial institutions, insurance intermediaries, non-bank financial institutions, brokers, real estate agents, cryptocurrency exchanges, gambling operators, and other entities defined under Law no. 129/2019.

An effective AML program starts with an assessment of business-specific risks. Based on this, internal policies and procedures are defined and updated, staff receive regular training, and transactions are monitored with suspicious activities reported. All measures must be documented and regularly reviewed to reflect legislative and operational changes.

AML risk assessment involves analyzing client profiles, transaction types, offered products and services, as well as the jurisdictions involved. It must be reviewed at least annually or whenever significant legislative, operational, or risk changes occur to ensure the compliance program remains effective and aligned with current risks.

By implementing and maintaining a robust framework for preventing and combating money laundering. This includes, at a minimum:Documented and updated internal policies and proceduresPeriodic reports to managementRegular employee training on AML risksContinuous monitoring of transactions and reporting of suspicious activitiesMaintaining a coherent and transparent system allows the entity to demonstrate due diligence and compliance with the law during any inspection or audit.