If your company’s economic activity falls under any of the categories listed below, you are required to implement an Internal Control System (ICS) and provide employee training.
It is worth noting that the companies listed below retain their status as entities subject to the AML (Anti-Money Laundering) Law even during insolvency or liquidation proceedings.
Entities subject to the AML (NILLTPFN) Law include:
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Credit institutions
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Insurance companies or intermediaries providing life insurance or other insurance services related to fund accumulation
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Private pension funds
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Investment brokerage companies
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Investment management companies
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Companies dealing with the purchase and sale of foreign currency in cash
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Payment institutions
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Electronic money institutions
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Credit unions
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Alternative investment fund managers
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Reinsurance service providers
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Financial leasing service providers
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Companies engaged in consumer credit services licensed by the Consumer Rights Protection Centre (PTAC)
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Outsourced accountants, sworn auditors, audit firms, and tax consultants, as well as any other individuals offering assistance on tax matters or acting as intermediaries in such matters, regardless of frequency or remuneration
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Sworn notaries, sworn advocates, and other independent legal service providers assisting in planning or executing transactions, participating in transactions, or conducting related professional activities on behalf of clients regarding:
a)
Buying or selling real estate or commercial entity shares
b)
Managing client money, financial instruments, or other assets
c)
Opening or managing accounts at credit or financial institutions
d)
Establishing, managing, or ensuring the operation of legal persons or entities, as well as contributions for such purposes
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Service providers for establishing and ensuring the operation of legal entities or formations
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Real estate dealers
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Lottery and gambling organizers
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Companies providing cash-in-transit services
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Private or legal entities trading or brokering transactions involving vehicles, cultural artifacts, precious metals, gemstones, or other goods, including related services, if the payment is made in cash or deposited into the seller's account in cash in amounts of €10,000 or more
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Debt collector service providers
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Crypto-asset service providers
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Individuals involved in trading, importing, or exporting art and antiques, including those operating in antique shops, auction houses, or ports, if the transaction amount or related transactions total €10,000 or more
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Insolvency process administrators