Regulate under the AML/CFT Law factoring activities, companies issuing meaning of payments such as credit and debit cards, and electronic money institutions.
Issue regulations (FMS decrees) for leasing activities.
Pass legislation on the issuing of bearer instruments (e.g., bearer checks).
Either regulate or prohibit the use of numbered accounts.
Remove the identification threshold for customers in order to ensure all customers are identified and verified when establishing business relationships.
Introduce a requirement in the AML/CFT law for FIs to understand the ownership and control structure of the customer.
Introduce a requirement in the AML/CFT Law to terminate the business relationship where the financial institution has commenced the business relationship and is unable to comply with CDD requirements.
Amend the AML/CFT Law explicitly stating when simplified measures may be applied. Such measures should only be allowed for countries that effectively apply FATF recommendations.
Amend the AML/CFT Law to prohibit applying simplified CDD measures when there is a suspicion of ML/FT or in cases of high risks.
Ensure that FIs look back at all existing customers and apply CDD procedures according to the new AML/CFT Law on a risk basis.
Ensure effective implementation of the measures on the identification and verification of the beneficial owner and on the information of purpose and nature of business.
Ensure that full CDD measures are applied to all existing customers.
Regulate the cases where FIs may complete the verification of the identity of the customers and beneficial owner after the establishment of the relationship.
Ensure that EDD apply when PEPs are beneficial owners of legal arrangements
Ensure that financial institutions take reasonable measures to ascertain the source of wealth of the customer and their compliance with the new AML requirements for PEPs.
Ensure that FIs apply enhanced ongoing monitoring in business relationships with PEPs.
Require that financial institutions that engage in correspondent banking activities document the respective responsibilities of each institution.
Ensure that correspondent relationships are approved by senior management.
Ensure that financial institutions periodically monitor their correspondent banking relationships with respect to AML/CFT issues and assess the possible reputational risks arising from those relationships.
Clarify that, when determining the reputation of a respondent institution, financial institutions should also determine from publicly available information if the respondent institution has been subject to a money laundering or terrorist financing investigation or regulatory action.
Ensure that entities have in place identification and verification procedures and develop enhanced measures to control and mitigate non-face-to-face business relationships and the use of new technology risks for all FIs.
Ensure that entities apply adequate ongoing CDD to non-face-to-face customers.
Clarify and issue guidelines on the use of non-face-to-face channels.
Ensure that AML/CFT provisions cover the operations regulated in the Instruction on Opening of an Account and Foreign Currency Operation which allows under certain circumstances to open a current account without physical presence and send the documentation by postal mail.
Ensure that AML/CFT provisions cover all electronic payment systems, including electronic payment points and electronic money institutions.