Transactions with high-risk third countries

On 31 October 2021, the amended Act on Combating Money Laundering and Terrorism Financing will come into force.

One of the amendments concerns relationships and transactions between our clients and high-risk third countries (Article 44 (1) and Article 44a of the Act).

In accordance with the amended Act, from 31 October 2021 we will be obliged to apply enhanced due diligence measures if a client’s transaction is connected with a high-risk third country.
This means that:
a)    we may place incoming and outgoing transfers on hold for up to five business days,
b)    we will ask our clients to provide:

  • additional information and documents regarding the transaction (e.g. an invoice), and
  • information on the source of their assets and funds, and all their beneficial owners.

If we do not receive the above information and documents within a specified time limit, we will not be able to execute a transaction placed on hold; as a measure of last resort, we may even terminate the relationship with such a client.

A valid list of high-risk third countries can be found here.


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