Law 129/2019 requires reporting entities to have a set of internal policies and procedures — but the exact composition and level of detail vary depending on each company's size, nature of activity, and risk profile.

We draft this documentation tailored to the actual specifics of your business, not from a generic template downloaded off the internet.

What AML Procedures Are

AML procedures are the internal documents through which a company demonstrates, in writing, how it applies AML legislative requirements in its daily activity. They are not an assessment (as with Consultancy), nor a review (as with Audit) — they are the concrete deliverable a reporting entity must be able to produce when requested.

What Documents/Procedures May Be Included

(The actual documentation depends on the entity's profile and the requirements applicable to your business — not all of the items below apply in the same form to every company.)

• The company's internal AML policy

• Know-Your-Customer (KYC) procedure

• Risk assessment methodology, tailored to the sector of activity

• Transaction monitoring and suspicious-transaction identification procedure

• Internal register of checks and reports

Together, based on your specific business, we determine which of these elements are relevant and what level of detail is appropriate.​

How These Are Tailored to Your Company

These documents aren't a fill-in-the-blank template. A real estate agency needs different procedures than an accounting firm or a notary — client types, specific risks, and transaction flows differ, as do the legal requirements applicable to each sector.

Each set of procedures is built starting from the company's actual activity, not from a generic model.

Who Needs This Service

• Companies that don't yet have the required base documentation

• Companies with old or generic procedures that no longer reflect their actual activity

• Newly established companies that fall under AML legislation

When You Need Written Procedures​

If you've already been through the orientation stage (Consultancy) or already know your business is covered by Law 129/2019, but you don't have written documents suited to your profile, this is the right service — whether you're starting from scratch or updating something outdated.

Why AML Expert

AML Expert's services are backed by over 20 years of experience in the field, including a period spent as Director of Supervision and Control at ONPCSB — a direct understanding of what inspectors actually check during an inspection, not just theoretical knowledge of the legislation.

Frequently Asked Questions

Are all of these documents mandatory for my company?

Law 129/2019 requires a base set of policies and procedures for reporting entities, but the exact composition and level of detail vary depending on the size, sector, and risk profile of your business. Together, we determine which documents are relevant to your specific situation.

What is the difference between procedures and an AML audit?

An AML audit checks whether existing procedures are correctly applied. Procedures are the documents themselves, drafted before they can be reviewed.

Do I need consultancy before ordering procedures?

Not necessarily — if you already know your business is covered by AML legislation, you can request the procedures directly. If you're not sure, AML consultancy is a useful step beforehand.

Who handles applying the procedures after they're drafted?

Drafting the documents is the first step. Ongoing maintenance and monitoring of their application falls under the AML Compliance service.

Do procedures also include ongoing strategic support?

Not directly — for ongoing decision-level advice, see the AML Advisory service. Procedures are a concrete deliverable, not an ongoing relationship.