AML/CFT development since introduction of the 3rd EU AML

Directive

5-6 of November, 2009Tallinn

Regulatory AML/CFT framework

Law of the Republic of Lithuania on the Prevention of

Money Laundering and Terrorist Financing

Resolutions of the Government of the Republic of Lithuania

Other legal acts (e.g. Law on Commercial Banks of Lithuania)

Group AML/CFT requirements

Controlling institutions

The Bank of Lithuania

The Financial Crime Investigation Service (aka FIU)

The Securities Commission of the Republic of Lithuania

Insurance Supervisory Commission of the Republic of

Lithuania

What are key AML/CFT requirements?

Identification of

beneficial owner

Politically

Exposed

Person?

Customer risk scoring

Monitoringofcash operations

Screening against sanction lists

Keeping the Register on transactions and regularly

submitting it to FIU

Reporting SAR/STR to FIU

Regular AML/CFT

training for staff

Brief overview of AML/CFT efforts

KYC due diligence (Beneficial Owner, PEP)

High risk customers’ adoption committee

New Products’ Approval Committee

Screening against designated sanction lists

Automated monitoring of financial transactions in order

to identify suspicious activities

Class room/e-training for staff

Main AML/CFT challenges

Staff’s reluctanceto ask inconvenient questions

Dissatisfied and irate

customers

Identification of beneficial

owners

Due diligence of foreign nationals

Feedback from FIU

Intricacies of automated monitoring systems

Exchange of information about blacklisted customers

Thank you for your attention!