Guidelines for evaluating the risks associated with money laundering have been completed and were published today. The process was initiated by FinanceEstonia, a financial sector representative organisation in Estonia. The specialist work group was led by our finance and insurance law senior associate Monika Tomberg.
Focus on supporting companies
The purpose of the guidelines is to support companies in evaluating the risks associated with AML and terrorist financing. The guidelines have been reviewed by the Estonian Financial Supervision and Resolution Authority, Financial Intelligence Unit and the Ministry of Finance. “We hope these guidelines will serve as a quality mark of sorts for the cooperation of Estonian businesses in fighting money laundering,” explained Monika.
Four types of risks
Based on acknowledged practice, the new guidelines divide risks associated with money laundering into four categories:
- Risks associated with customers;
- Risks associated with countries or areas of operation;
- Risks associated with products, services or transactions;
- Risks associated with communication channels.
In the guidelines, specific possible factors affecting the level of risk for each category are included together with explanations. A total of 60 different risk factors have been reviewed in the guidelines, based on the practice and experience of Estonian creditors.
Significant need for cooperation
According to the authors, there is a significant need for trans-sectorial cooperation and an overall improvement of reputation of the field. Estonia will also be assessed by Moneyval, a monitoring body of the Council of Europe focusing on AML and countering terrorist financing, in the coming months. The assessment will look into companies’ activities in preventing money laundering and financing terrorism. The guidelines are therefore a long-awaited resource for companies in the finance sector.
The guidelines have been prepared by Monika Tomberg (Sorainen), Gerly Lõhmus (IPF Digital), Kadri Erm and Fred Sooläte (Placet Group), Kadri Uus (Hüpoteeklaen), Janika Vilms and Ants Soone (LHV), Sirli Nellis (Bigbank), Hetti Lump (KPMG Law) and PwC Legal.