On 9 January 2020 the State Agency National Security ("SANS") published on its web site important documents and information for the obliged entities under the Measures against Money Laundering Act ("MAMLA").
Results from the National Risk Assessment
The SANS published the results from the National Risk Assessment prepared according to the requirements of the MAMLA and analyzing the country's external and internal risks from money laundering and terrorist financing.
Pursuant to § 6, Para. 1 of the Transitional and final provisions of the MAMLA, the obliged entities shall amend their internal rules according to the MAMLA and the results from the National Risk Assessment within 6 months as from the date of their publication, i.e. not later than 9 July 2020.
The obliged entities are released from the obligation to submit their annual training plans to the SANS
In relation to the last amendments in the MAMLA, effective as of 3 December 2019, amendments have been prepared in the Rules for Implementation of the MAMLA. One of the amendments envisages that the obliged entities shall be released from their obligation to submit to the SANS their annual plans for training of the employees by 15th of February of the year for which they refer.
As per the instructions of the SANS the obliged entities do not have an obligation to send their annual training plans for 2020.
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