As we step into the new year, we often look forward rather than back. However, to ensure you don’t miss anything important, we’d like to remind you of significant updates.
For instance, on December 30, 2024, an amendment to the AML Act came into effect, introducing changes to the rules for reporting a contact person. This refers to an employee or a member of the statutory body through whom obligated entities report suspicious transactions to the Financial Analytical Office (FAÚ) and communicate with it.
Under the amendment, all obligated entities (with exceptions for certain specific entities, such as attorneys, notaries, or specific art dealers — a list of affected entities is available here) must now notify the FAÚ of their designated contact person, including those that had already fulfilled this obligation previously. Obligated entities must also provide new information on the hours during which the contact person can be reached, ensuring this timeframe aligns with the hours during which the entity conducts transactions. Furthermore, the timeframe for notifying the FAÚ has been significantly shortened: 30 days for initial notifications of new obliged entities and 15 days for changes to previously reported information, compared to the previous deadlines of 60 and 30 days, respectively.
The contact person’s details must be reported using a specialized form, which will be available on the FAÚ website starting February 1, 2025. According to the amendment, this form must be submitted to the FAÚ exclusively via the data mailbox system.
The obligation to notify the FAÚ of the contact person under the new regime will apply from February 1, 2025, when the Ministry of Finance decree specifying the format and structure of submissions to the FAÚ takes effect. Existing obliged entities must comply with this obligation within 30 days of the Decree coming into force, by 3 March 2025 at the latest.
By Michaela Smotkova, Associate, JSK , PONTES
