Custom AML Procedures for Companies in Romania - Complete Guide
What Are AML Procedures
AML procedures are the internal documentation through which a company defines how it prevents money laundering: customer identification (KYC), risk assessment, transaction monitoring, and reporting of suspicions. They are not just formal documents - they are the foundation of AML compliance.
What AML Procedures Should Contain
A complete AML procedure should include: Know Your Customer (KYC) policy, risk assessment, transaction monitoring, reporting to ONPCSB, the AML officer's role, and staff training.
What a Good AML Procedure Looks Like
A good AML procedure is not a generic model copied from the internet. It must be tailored to the company's activity and clearly include customer identification, risk assessment, monitoring, reporting of suspicions, and the steps to follow during an inspection.
Template vs. Real Procedure
A template is generic, copied, and not adapted. A real procedure is tailored to the company, based on risk, and applicable in practice. Most fines stem from this difference.
What You Risk Without Proper Procedures
Fines between 25,000 and 150,000 lei for legal entities, plus up to 10% of total reported revenue depending on the situation; additional obligations; and reputational risk.
Conclusion
AML procedures are not just a mandatory document. They are the foundation of compliance, the first thing checked during an inspection, and the main factor protecting you from fines. If they aren't tailored to your company, they aren't effective.
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