AML programme

What it means

A programme of own activity is an internal document that every obliged entity must have under the Slovak anti-money laundering law. It describes how the company fulfils its AML duties in practice and serves both as a guide for staff and as evidence for inspectors.

The law sets its minimum content. It includes a description of how clients are vetted under KYC, a risk assessment by type of client, product and country, an overview of the forms of unusual business transactions typical for the company’s activity, the procedure for detecting and reporting them, and how records are kept.

It also designates the person responsible for compliance and for reporting to the financial intelligence unit, and sets out the procedure for refusing a transaction, rules for staff training and how compliance with the programme is checked. The document must be in writing and kept up to date.

How it works in practice

We maintain a programme for our own firm and help clients who are obliged entities, such as estate agents or car dealers, prepare theirs. We start from a template but adapt it to how the specific company really operates, its clients and its products.

A key part is a list of typical red flags for the activity concerned. For an accounting firm, that might be a client who frequently switches banks, cannot explain the origin of deposits or pays for services from a third party’s account. For an estate agent, a property bought in cash or through an opaque structure.

The programme must be updated when the law changes, when the company’s activity changes and after the national risk assessment. Staff dealing with clients must read it when they join and receive regular training, which should be documented in writing.

What to watch out for

The most common mistake is a programme downloaded from the internet and never adapted. In an inspection, the financial intelligence unit checks whether the programme matches the real activity and whether staff know it. A formal document nobody uses will not pass.

A missing or outdated programme is a breach of the law in itself and may be fined, even if the company never missed an unusual transaction. Failing to keep records of training and of client assessments, for example of politically exposed persons, is equally risky.