How to report suspicous ML/TF activity

If you are an obliged entity listed under Article 4 of the the AML/CFT Law you are obliged to establish such as system that allows you to know your client and monitor their operations in such a way to be able to detect unusual and suspicious transactions.


AML/CFT supervisory authorities (listed in Article 104 of the AML/CFT Law) develop lists of indicators to recognise persons or transactions with respect to which there are reasons of suspicion on money laundering or terrorist financing, and these lists are published on our website.  The obliged entity is required to develop their own list of indicators, also incorporating the indicators developed by the supervisory authorities.

When developing the indicators, the obliged entity must consider the complexity and size of transaction, unusual method of conducting the transaction, value of or connection between transactions which do not have economic or legal purpose, and/or are not in line with or are in disproportion with usual and/or expected business activities of the client, as well as other circumstances related to the customer’s status or other characteristics.

In addition to applying the list of indicators when determining whether a person or activity is suspicious or not, the obliged entity must also consider other circumstances potentially presenting reasons for suspicion on money laundering or terrorism financing.

If you are a person other than the obliged entities under the AML/CFT Law and you think someone is laundering money or finances terrorism, you should report your suspicion to the police or prosecutor’s office.

The APML is not responsible, under the AML/CFT Law, for receiving notifications from natural or legal entities outside those listed as obliged entities under the AML/CFT Law. However, should we receive such information, we shall transmit it to the competent authority.