Amendments to the Measures against Money Laundering Act

Amendments to the Measures against Money Laundering Act

Amendments to the Measures against Money Laundering Act (MAMLA) regarding the transposition of Directive (EU) 2018/843 ("Fifth Directive") were promulgated in the State Gazette, issue 94, dated 29 November 2019. The amendments are effective as of 3 December 2019.


The obliged persons under the MAMLA need to align their internal rules with the changes in the law.

The most important amendments are as follows.

A list of the positions qualified as "politically exposed persons"

The State Agency National Security will draft and present to the European Commission a list of the positions which qualify as "politically exposed persons". The list may be made public.

Specific measures for enhanced due diligence of persons from high-risk countries

Specific measures have been introduced for enhanced due diligence of the business relationships, operations and transactions with persons from high-risk countries. The measures include collection of additional information about the clients and their beneficial owners, the nature of the business relationships, the source of funds and source of wealth.

Introduction of new categories of obliged persons

New categories of obliged persons have been introduced in the scope of the MAMLA:

  • persons storing, trading or acting as intermediaries in the trade with art works when the deal value or linked deals value is equal to or exceeds EUR 10,000;
  • persons providing professional services of exchange of virtual currencies and fiat currencies;
  • custodian wallet providers, i.e. persons providing services to safeguard private cryptographic keys on behalf of their clients to hold, store or transfer virtual currencies.

The persons specified in the last two bullets above need to be registered in a public register maintained by the National Revenue Agency. The registration is to be made under terms set out in an ordinance issued by the Minister of Finance.

For questions, please do not hesitate to get in touch with us.

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