Money laundering prevention in the non-financial sector

The topics are discussed and illustrated with examples tailored to the industries of the seminar participants, e.g. for the commercial goods trade such as the automobile, boat and precious metal trade, art brokers and gallery owners, as well as real estate agents, notaries, financial companies and insurance brokers.

Current legal situation  

Short introduction

• Current European and national legal framework.  
• Basic principles of money laundering prevention, e.g. risk-based approach.
• Structure of the Money Laundering Act (GwG), legal ordinances; other laws.
• Knowledge nuggets: National risk analysis, FIU, AuA supervisory authorities.

Risk management

• Risk analysis; customer profile assessments.
• Internal security measures with Group-wide procedures.
• Appointment of money laundering officers.
• Informing Employees,
• Documentation and retention obligations.

Core area of customer due diligence obligations

• General, enhanced and simplified due diligence obligations with examples.
• Beneficial owners, politically exposed persons, high-risk countries.
• contractual outsourcing to third parties.

Transparency register and suspicious activity reports

• Transparency obligations; discrepancy report; information on real estate.
• Reporting obligations; electronic reporting portal; suspicious activity reporting procedure.

Money laundering supervision

• Duty to cooperate, whistleblower systems, data privacy, publication of final measures by supervisory authorities.

Practical implementation of the MLA

• Your personal "awareness program" for the first 100 days.

• Best practices - examples of suspicious transactions; your examples.

Future legal situation

EU legislative package

• New Money Laundering Ordinance (AML Ordinance).
• new Money Laundering Directive (AMLD6).
• Revised Ordinance on the Transfer of Funds Ordinance.
• Establishment of the European Anti-Money Laundering Authority (AMLA).