ILA ad hoc task force on AML/CFT matters

Dear all,

Since the publication of the guidelines on registration requirements for trust and company services providers (“TCSP”) under the AML/CFT Law of 2004 by the National Prevention Committee (“NPC”) in October 2021 (the “Guidelines”) and during the online presentation of these Guidelines in November 2021, many members have approached us to share their questions on these guidelines and seeking guidance on specific elements reflecting their activities. 

The ILA ad hoc task force on AML/CFT matters, which was consulted extensively in the elaboration of the Guidelines, has collected these questions and has prepared, together with the Executive Secretariat of the NPC a Q&A document, which we are happy to share today with the members of ILA.

The Q&A document addresses general questions which are believed to reflect the operational set-up that should be familiar to a considerable number of our members. The Q&A document should be read in conjunction with the Guidelines as they represent ILA’s understanding of the concepts expressed in these Guidelines.

Although ILA believes that giving its members access to information and guidance allowing them to fully understand their obligations under applicable AML/CFT regulations, this Q&A document shall not be considered as legal advice and members in doubt about their individual situation are encouraged to seek specialist advice.

ILA strongly encourages its members who reach the conclusion that they are performing TCSP services to undertake all necessary formalities to ensure full compliance with applicable AML/CFT regulations without undue delay.

If the regulatory framework applicable to AML/CFT evolves or if new questions are raised by our members, ILA will update the Q&A document to share updated information with its members.

We hope that you find this Q&A instructive and wish you a good and relaxing summer break.

With best regards,

Joachim Kuske
on behalf of the ILA ad hoc task force on AML/CFT matters