What AML Documents Should a Company Have
If your company falls under Law 129/2019, it's important to know which AML documents must exist and be kept up to date. Missing documentation can cause problems during an inspection.
What AML Documentation Means
AML documentation is the set of procedures, policies, and internal measures through which a company demonstrates compliance. These documents must be tailored to the company's activity and updated periodically.
What AML Documents a Company Must Have
In practice, the most important AML documents are: internal AML procedures, the AML risk assessment, KYC policies and customer verification, monitoring and reporting measures, staff training documentation, and records of checks performed.
What Authorities Check in Practice
During an inspection, they frequently review: the existence of AML procedures, the risk assessment, customer documentation, application of KYC measures, and the traceability of checks performed.
Most Common Issues
Procedures copied from generic templates, outdated documents, missing risk assessments, and incomplete customer checks. These can lead to non-compliance findings and sanctions.
Conclusion
AML documents should not be treated as a mere formality. They must reflect the company's actual activity and demonstrate correct application of legal obligations.
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