CMS Expert Guide to AML/CTF in Central and Eastern Europe

Overview of relevant laws and regulations


In order to maintain the integrity of financial markets and prevent corruption and terrorism, it is necessary for all governments to take a robust approach to money laundering and terrorist financing and a coordinated global approach is also essential.

The European Commission as well as other international organisations have issued directives and general guidance on standard rules and regulations to support this ambition. The Commission ensures effective application of the anti-money laundering and counter-terrorist financing legislation by the EU Member States, and it promotes the adoption of global solutions at an international level. More and more countries are members of the international bodies concerned with combating money laundering and terrorist financing, and comply with their binding standards.

The situation in Central and Eastern Europe has an impact on the rest of Europe. Some CEE countries have a geostrategic location as entry points into Europe, and therefore strict observance of the standards and efficient enforcement in the region is crucial. In this report, CMS experts have looked into key topics covering twelve Central and Eastern European Countries, namely Bulgaria, Croatia, Czech Republic, Hungary, Montenegro, Poland, Romania, Russia, Serbia, Slovakia, Slovenia and Ukraine. We provide an overview on relevant acts and regulations, details of supervising authorities, and reporting obligations. We also outline the criminal, regulatory and other risks that corporates may face in case of non-compliance with local AML/CTF laws.

This publication reflects the implementation of the 4th AML Directive and the 5th AML Directive by the CEE countries, as these directives are defined in the Legal Note below. 

The publication does not constitute legal advice. All legal matters must be decided on a case-by-case basis, in light of all circumstances and should be subject to a thorough legal assessment under local law.

For detailed legal advice, please contact our experts in the relevant jurisdictions, whose details are set out in this report.

Legal Note

The 4thAML Directive: Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation (EU) No. 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC, OJ L 141, 5.6.2015, p. 73–117.

The 5th AML Directive: Directive (EU) 2018/843 of the European Parliament and of the Council of 30 May 2018 amending Directive (EU) 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, and amending Directives 2009/138/EC and 2013/36/EU, OJ L 156, 19.6.2018, p. 43–74. 

The 6th AML Directive: Directive (EU) 2018/1673 of the European Parliament and of the Council of 23 October 2018 on combating criminal law money laundering, OJ L 284, 12.11.2018, p. 22–30. The 6th AML Directive is due to be implemented into national law by 3 December 2020. This Directive will establish minimum rules concerning the definition of criminal offences and sanctions in money laundering across the EU. 

Authors

Erika Papp
Head of Finance CEE/CIS
Image of Elitsa Ivanova
Elitsa Ivanova
Head of Finance
Photo of Iain Batty
Iain Batty
Head of Commercial in CEE
Picture of Nevena Radlova
Nevena Radlova
Head of Competition and IP
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