Are you required to appoint an anti-money laundering officer and a deputy in accordance with the Money Laundering Act? Then you need to weigh things up: Money laundering officers are special employees in every company where they have to be appointed. In addition to any other duties they may have, they must monitor compliance with money laundering regulations throughout the company. This is easier said than done, as it requires special training, authority, systems support and communication skills. The tasks of money laundering officers are complex, the appointment must be made at management level and they are also subject to special protection against dismissal.
Due to the high additional burden for employers and companies of appointing money laundering officers, the legislator allows the outsourcing of this obligation to qualified third parties. This saves you personnel and training costs and at the same time protects you against money laundering - but also against employees who cannot be dismissed - through our professional service.
Kerberos provides professional external money laundering officers to all obligated parties under the Money Laundering Act. Contact us now for a no-obligation consultation.
By appointing an external money laundering officer, you save time and money, regardless of whether you have to appoint a money laundering officer due to legal obligations or official requirements.
Our certified money laundering officers are professionally qualified and always up to date with the latest legal requirements. As a provider of comprehensive solutions for money laundering prevention, we work in an area of law that is updated more frequently than almost any other. Accordingly, it is essential for us to incorporate all current developments into our products. In this way, we also meet the requirements of the supervisory authorities with regard to the outsourcing of obligations to third parties.
The cost efficiency results from the elimination of training and further education for your employees. In addition, you also save on setting up your own anonymous whistleblower systems, training, documentation as well as communication with authorities and much more.
We are service providers and enter into service contracts with you. Special notice periods, such as those to which internal money laundering officers are subject, are not provided for external money laundering officers.
As external money laundering officers, we take on all the tasks that this position entails - including the appointment of a deputy. The only difference to internal money laundering officers is that we can do this for you more cheaply, digitally and quickly.
In addition, as a professional money laundering prevention provider, we can identify your obligations on an industry-specific basis and take appropriate action. In the case of the submission of money laundering suspicious activity reports, for example, there is no clear indication on the part of the supervisory authorities as to exactly which concrete conditions oblige the submission. Accordingly, there is always a need for individual case evaluations and concrete risk assessments, which we can carry out for you.
Our services as external money laundering officers include:
Money laundering officers are permanent contacts for the topic of money laundering prevention and compliance in your company. The requirements that money laundering officers must meet are not precisely defined by law. However, the money laundering officer and his/her deputy must be highly qualified, accepted by the authorities and checked for reliability. Although they are responsible for compliance with money laundering regulations within a company, this does not release the management level from their personal responsibility in the event of violations of the Money Laundering Act. The scope of duties of the money laundering officer primarily includes measures for compliance with money laundering regulations, such as the preparation of risk analysis, training supervision, the development of guidelines and many other obligations under money laundering law. They also review and process suspected cases under money laundering law and report them to the competent authorities. Furthermore, they are in close contact and constant exchange with the authorities.
Who is obliged to appoint a money laundering officer is regulated in § 7 of the Money Laundering Act. This includes various financial service providers and institutions, insurance companies, capital management companies and organisers and brokers of games of chance. However, real estate agents, dealers in goods, notaries and lawyers as well as other obligated parties may also be required by the supervisory authorities to appoint money laundering officers if they deem it appropriate. This is particularly the case if the obligated parties deal in high-value goods or if certain thresholds are reached when brokering contracts.
If you are unsure whether you are obliged to appoint a money laundering officer, we would be happy to advise you in a non-binding initial meeting.
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