Reporting agents within the meaning of the Anti Money Laundering Act are obliged to collect and store information about their customers separately from other customer information. The application of the law is currently familiar to companies, mainly because banks ask strange and, in some cases, intrusive questions. Now, accountants, auditors, law firms, attorneys, real estate agents, and many other companies that provide business services have to ask these same questions.
Compliance with the law has been relatively superficial outside the financial sector in Finland. So far only the largest actors in accounting, auditing and the legal side have realized the importance of complying with the legal obligations.
However, law enforcement will be strengthened by the Money Laundering Control Register, in which all notifiers must register their data. The register has received very little publicity and a large number of actors covered by the law are not even aware of their obligation to register. There are probably a large number of small players that are not reached by, for example, the Finnish Financial Management Association or the Finnish Bar Association.
The original deadline for registration in the register was 14th of July 2019. However, the Regional State Administrative Agency of Southern Finland states on its website that due to the delay in the application form, they will not be actively monitoring the implementation of the registration obligation, and will only start to map out omissions later in the fall.
The biggest surprise in the register of notifiers is its fee. Each notifier, who is supervised by the avi of Southern Finland, has to pay 200 euros for joining the register. The higher fee of 355 euros will be paid by currency exchangers and business service providers.
What changes with the registry? Statutory obligations are not affected by joining the register. The register facilitates the provision of information and guidance to the supervisory authority. The AVI of Southern Finland has doubled its supervisory resources to ten inspectors during the spring and summer. For example, a request may be made to submit to the supervisor for review the statutory risk assessment specified by law, which the reporting entities must have and keep continuously updated. The risk assessment describes, for example, the accountant’s actions against money laundering and the fight against the financing of terrorism.
Now, lawyers, accountants, auditors and collection teams. Spend your holiday in peace and visit the Southern Finland AVI website in August at the latest. http://www.avi.fi/web/avi/rahanpesun-valvontarekisteri
Jukka Kojola 7/12/2019
The author is the Chairman of the Board of Clento Oy.