LKS Consult

KYC/AML Officer Services

As part of the fight against financial crime, governments around the globe require financial institutions to implement Anti Money Laundering (AML) programs to combat money laundering. In order to monitor internal anti-money laundering policies and comply with important regulations, banks and other financial institutions will designate an AML Compliance Officer.

When applying for a single cryptocurrency license, a KYC/AML Officer is required for an Estonian company.

Main responsibilities

  • Assist in the development, implementation, and maintenance of an anti-money laundering program of the respective institution.
  • Organisation of collection and analysis of information on suspicious transactions or transactions where there is a risk of money laundering or terrorist financing.
  • Submission of written statements on compliance with the requirements of the law to the management of the virtual currency exchange service provider or the virtual currency wallet service provider entered into the Estonian Commercial Register.
  • Maintenance of High-Risk customer records and reporting suspicious activity to authorities.
  • Reporting to the Financial Intelligence Unit (Rahapesu andmebüroo) in case of suspicion of money laundering or terrorist financing.
  • Development and maintenance of a risk assessment system for products and service and customers, as well as for other issues related to money laundering.
  • Monitoring and implementation of an ongoing AML training program for other employees.
  • Briefing and reporting to senior management on internal AML policies and procedures.
  • Organisation of third-party inspections and audits, and development of compliance guidelines.

KYC/AML Officer takes due diligence measures:

  • When establishing business relations with a new client.
  • When making payment in the amount of more than 15,000 EUR or an equal amount in another currency.
  • When verifying data in case of doubts about the reliability of submitted documents or data.
  • In case of suspected money laundering or terrorist financing.

AML Compliance Officer’s role

A Compliance Officer is responsible for implementing the prescribed regulations at the institutional level. The specialist’s professional focus is set on the internal systems and controls that an institution uses to detect, monitor, and report money laundering activities to authorities. The main task of a KYC/AML Officer is to ensure that an organisation is not exposed to criminal risk and does not inadvertently contribute to financial crime.

AML Compliance Officer’s designation

AML compliance is an ever-evolving area, so your AML specialist’s expertise should reflect the current regulatory framework. Given the importance of the AML program, your Compliance Officer should have all the necessary knowledge and skills in the areas of financial policy and KYC/AML procedures, as well as in methodologies for dealing with financial irregularities. It is important that the Management Board selects a candidate who not only has the ability and experience to carry out their duties effectively, but also meets the unique professional requirements of an organisation.

A Compliance Officer not only monitors and processes various sensitive financial data, but also regularly interacts with the Board of Directors as well as financial authorities. In addition, your company’s KYC/AML Officer must have sufficient authority to ensure that their duties are performed effectively. Ideally, an AML specialist should be a director-level employee with industry experience to deal with all aspects of their professional environment.

 

LKS Consult OÜ offers the services of an experienced KYC/AML Officer (an Estonian citizen) with knowledge of all relevant Estonian requirements and laws for the identification of clients of your cryptocurrency project.

KYC/AML Officer services (minimum service period – 1 year) 2,000 EUR/month
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FREQUENTLY ASKED QUESTIONS

  • What position should a KYC/AML Officer occupy in the company?
    The Compliance Officer is either an employee of the company or is a part of the governing body, that is, the Board of Directors of the company. It is also possible to order this service from a third-party company.
    The duties of the AML Officer can be performed by an employee or a structural unit. If the tasks of the contact person are carried out by the structural unit, then the Head of that structural unit is responsible for completing the tasks of the Compliance Officer.
    The RAB and the competent supervisory authority are informed of the appointment of the Compliance Officer.
  • Who should a Compliance Officer answer to?
    The contact person of a financial institution is directly subordinate to the Board of Directors of the credit or financial institution and has the competence, resources, and access to relevant information in all structural divisions of the financial institution, necessary to fulfill the duties provided for in this Law. Also, the AML Officer should interact with state departments (in the case of an Estonian cryptocurrency company, this is Rahapesu Andmebüroo) and contribute to the fight against money laundering and reduce the risk of terrorist financing.
  • Is experience required to work as a KYC/AML Officer?
    Yes, it is desirable to have experience in this area. Only a person, who has the appropriate education, professional suitability, the necessary abilities, personal characteristics, experience, and impeccable reputation necessary to perform the duties, can be appointed as the KYC/AML Officer. The appointment of the KYC/AML Officer is coordinated with the RAB.
  • What if the company is not in compliance with AML requirements?
    If the company does not comply with AML requirements, then its licenses and permits may be revoked. If, as a result of a RAB review, it becomes apparent that the specialist’s credibility is in doubt as a result of their failure to act, that specialist’s reputation is not flawless, then the company may severely terminate the employment contract.
  • When does an enterprise need a Сompliance Officer?
    All crypto-companies must have a Compliance Officer. The Board of the financial institution, which is a cryptocurrency company, and the Head of a branch of a foreign credit institution, and a financial institution entered in the Estonian Commercial Register, appoints a specialist who is the contact person of the company with the RAB. The functions of the contact person include, in particular:
    1. Organisation and analysis of the information related to unusual transactions or circumstances suspected of money laundering or terrorist financing that arise in the activities of a mandatory person.
    2. Information forwarding to the RAB in case of suspicions of money laundering or terrorist financing.
    3. Submission of periodically written reviews of the claims arising from this law to the Board of the financial institution.
    4. Fulfillment of other obligations related to compliance with the requirements of the Law. (https://www.riigiteataja.ee/en/eli/ee/521122017004/consolide/current)
  • Can a KYC/AML Officer be outside Estonia?
    No, the company is required to appoint a local specialist. After the regulatory changes came into force on 1 July 2020, the Anti-Money Laundering Officer must reside in Estonia. The KYC/AML Officer has the right:
    1. to make proposals to the Board of the financial institution on amendments and additions to the rules of procedure containing the requirements for the prevention of money laundering and terrorist financing, as well as the organisation of training specified in subsection 14 (6) of the Money Laundering and Terrorist Financing Prevention Act;
    2. to demand, within a reasonable time, to liquidate the structural unit of the obligatory person in order to eliminate the deficiencies identified in the implementation of the requirements for the prevention of money laundering and terrorist financing;
    3. to obtain the information necessary to fulfill the duties of the contact person;
    4. to make proposals for organising the process of submitting suspicious and unusual messages;
    5. to complete the necessary training.
  • How are the application for a crypto-license in Estonia and the presence of a company’s KYC/AML Officer related?
    If you wish to apply for a single cryptocurrency license in Estonia, your company will need a KYC/AML Officer in Estonia.
  • How to find a suitable KYC/AML Officer for the company?
    LKS Consult OÜ offers the services of an experienced KYC/AML Officer (an Estonian citizen) with knowledge of all relevant Estonian requirements and laws for your cryptocurrency project. If your company has a contact person, LKS Consult OÜ can offer the training course on Money Laundering and Terrorist Financing Prevention Act.

Additional Information/BLOG:

AML officer in Estonia