The need for prevention and suppression of money laundering and terrorist financing has led Authorities at both the national and international level to adopt Regulations and Legislation to address these phenomena.
The complexity of the Anti-Money Laundering and Counter Terrorism Financing requirements and the ever-changing landscape of AML make it necessary to adapt and enhance the internal procedures of the obliged regulated persons, which amongst others include financial institutions, financial service providers, gambling and gaming operators, lawyers, accountants and other designated non-financial business persons to comply with regulatory and legislative changes.
The scope of AB Compliance’s high quality, specialized services is to fulfill the compliance needs of obliged persons and organizations, as required by the subject matter of the applicable law. Through our services we identify, evaluate and understand the risks involved in different sectors and industries and we provide guidance to obliged persons/entities in fulfilling their obligations under the laws and regulations on the prevention and suppression of money laundering and terrorist financing.
AML Consulting and AML Audits
Monitoring and assessment of the effectiveness of the policies, practices, measures, procedures and controls applied for the prevention of Money Laundering and Terrorist Financing. As part of these services AB Compliance may conduct physical visits to the client and evaluate the client’s relevant procedures and records.
Preparation and delivery of AML/Compliance seminars and training to Organizations
Preparation and delivery of seminars in relation to Anti-Money Laundering Laws and Regulations, as well as training, on each organization’s AML obligations in order to be compliant with the relevant legislation. Each seminar/training is designed in accordance with the specific needs of each organization and it is adapted to cater to the specific needs of the role and level of the participants within the organization.
Review, update and re-drafting of the Internal Anti – Money Laundering Manual
Tailor-made preparation/update of the Anti – Money Laundering Manual of the obliged entity to eliminate deficiencies and to keep up to date with any changes and updates of the Law.
Internal Anti-Money Laundering Audit Function for Obliged Entities
Assessment and evaluation of the obliged entity’s internal procedures and internal controls.
- Review and assessment of the general compliance of the obliged entity with the Law and directives on operating conditions requirements.
- Review and examination of the adequacy of the obliged entity’s client acceptance procedures.
- Review of the obliged entity’s compliance with its business obligations when providing administrative services.
- Review of the compliance of the obliged entity’s different departments with the relevant regulatory framework.
- Provision of independent assurance to the Board of Directors and Senior Management on the quality and effectiveness of the obliged entity’s internal control, risk management and governance systems and processes/procedures already in place.
- Preparation and submission of the Annual Internal Audit Report to the Board of Directors.
Preparation of Internal Capital Adequacy Assessment Reports (ICAAP)
Assessment of the obliged entity’s risks, based on its size, internal organization and the nature, scope and complexity of its activities, provision of advice as to how to mitigate those risks and how much current and future capital is necessary having considered the relevant risk and other mitigating factors.
Development and establishment of client acceptance policies:
- Customer Identification (KYC) and due diligence procedures
- Construction and content of clients’ economic profile
Development and establishment of Internal Reporting Procedures
Establishment of the procedure to be followed by the obliged entity in respect to Internal Reporting of suspicious transactions to the AMLC Officer.
Client On-Boarding services
- Development and establishment of a clear client on-boarding policy, which is in line with the provisions of the Law and directives, after a detailed assessment of the risks faced by the particular client. Such risks usually emanate from the obliged entity’s clientele, the type of transactions executed on behalf of clients, and the country of origin and operations of the clients. By taking into consideration factors such as the clients’ background, type and nature of their business activities, their country of origin, the services and financial instruments applied for, the anticipated level and nature of business transactions as well as the expected source and origin of funds, we establish a bespoke client acceptance policy, in which we explicitly set out the criteria for accepting new clients, identify the categories of clients who will not be accepted for the establishment of a business relationship and list the criteria for the risk categorization of clients.
- Undertaking the full range of client On-Boarding services (as described above) as an outsourcing supplier of the obliged entity.
Development and establishment of the risk management and procedures manual
Establishment of the procedures and risk management manual for the obliged entity to fulfill the specific needs of each entity based on its size, internal organization and the nature, scope and complexity of its activities.
Establishment of procedures for the ongoing monitoring of customers’ accounts and transactions
Establishment of procedures and methodologies in order to monitor account transactions for unusual behavior, as required by AML legislation.
Assessment and establishment of adequate governance arrangements to ensure effective and prudent management
Implementation of governance arrangements that ensure effective and prudent management of an obliged entity, including the segregation of duties within the organization and the prevention of conflicts of interest.
Preparation and implementation of Recovery and Resolution Plans
Preparation of a recovery and resolution plan providing for measures to be taken by the obliged entity in order to restore its financial position following a significant deterioration of its financial situation.
Recommendation of suitable AML Software
Recommendation of AML Software which is suitable for the specific needs of each obliged entity based on the entity’s size, internal organization and the nature, scope and complexity of its activities.
Greek Supervising Bodies & Obliged Entities
According to Greek legislation and depending on the sector and industry they operate, obliged entities are regulated by various supervising bodies. We set below a non-exhaustive list of the Greek Supervising Bodies along with the corresponding obliged entities under their supervision:
Bank of Greece
- Credit institutions
- Insurance undertakings and insurance intermediaries
- Leasing companies
- Factoring companies
- Credit management companies for loans and appropriations from credit institutions
- Credit companies
- Electronic money institutions
- Payment institutions
- Postal companies, in respect of the payment services provided
- Bureaux de change
Hellenic Capital Market Commission
- Unit trusts
- Mutual fund management companies
- Investment firms and their tied agents
- Stock brokerage firms
- Venture capital firms
- Real estate investment companies
- Alternative investment fund managers
Economic Police and Cyber Crime Unit (YP.O.A.D.I.E.)
- Money changers
Hellenic Accounting and Auditing Standards Oversight Board
- Chartered auditors-accountants
- Audit firms
Independent Authority for Public Revenue (A.A.D.E.)
- External accountants-tax advisors and legal persons providing accounting-tax services, as well as private auditors
- Real estate agents
- Dealers and sellers in high-value goods
Hellenic Gaming Commission
- Casino enterprises and casinos operating on ships in Greece or flying the Greek flag
- Businesses, organizations and other providers of gambling services and related agencies, including online betting platforms
Ministry of Justice, Transparency and Human Rights
Ministry of Economy and Development
- Traders and auctioneers of high-value goods, when the value of the transaction amounts to at least ten thousand (10,000) euros
- Undertakings operating in mining, production, processing and trading of precious and semi-precious stones
- Undertakings operating in the production, processing and trading of precious metals and derivatives
- Undertakings operating in trading of pearls and corals
- Undertakings operating in the manufacture and trading of jewellery and watches
- Undertakings operating in trading of antiques, antiquities, medals, old valuable stamps and currency and other valuable collectibles
- Undertakings or professionals operating in the production or manufacture and trading of art works and objects in general, and of musical instruments
- Persons trading or acting as intermediaries in the art trade, including trade taking place in art galleries and auction houses
- Undertakings operating in the production and trading of rugs and carpets, fur products and clothes, in general
- Undertakings operating in trading private passenger cars, helicopters, aircraft and recreational craft in general