Question 1

When do AML obligations apply to my office?

Accepted Answer

AML obligations attach to defined obliged entities — notaries, lawyers (for certain transactions), accountants, tax advisors, estate agents and company-service providers — when they carry out activities the law lists as in-scope.

Question 2

What is a PEP, and how do I check for one?

Accepted Answer

A politically exposed person (PEP) holds, or has held, a prominent public function — a minister, senior official, judge, senior military officer, or a director of a state-owned company. The definition extends to immediate family members and known close associates.

Question 3

Why sanctions screening can't wait

Accepted Answer

Unlike much of the AML framework, sanctions obligations are absolute: you may not do business with a listed person or entity, regardless of intent or risk appetite. They apply to every business, and breaches carry serious penalties.

Question 4

A UBO — what is it again?

Accepted Answer

The ultimate beneficial owner is the natural person who ultimately owns or controls a client — typically through a shareholding above 25%, or through control by other means. The point of AML is to see past the company to the real people behind it.

Question 5

Reporting an unusual transaction: what, when, how

Accepted Answer

When you know, suspect or have reasonable grounds to suspect money laundering or terrorist financing, you must report to the financial intelligence unit — in Belgium, CTIF-CFI — promptly, and before completing the transaction where possible.

Question 6

AMLR 2027: what changes for obliged entities

Accepted Answer

The AMLR replaces much of the patchwork of national transpositions with a single, directly-applicable EU rulebook from 10 July 2027. Because it is a regulation, not a directive, its core rules apply uniformly without waiting for national law.

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