Anti-Money Laundering (AML/CFT) Services in Romania & Internationally

I design and implement AML/CFT compliance frameworks tailored to your organization’s business model, size, customer profile and specific ML/TF risk exposure, in line with applicable Romanian and EU requirements, including Law no. 129/2019, relevant ONPCSB regulations and guidance, EU AML/CFT legislation and FATF standards. I can develop a complete AML/CFT program from the ground up or review and update an existing framework to address regulatory changes, identified gaps or changes in the business.

Depending on your organization’s needs, the engagement may include the development or revision of the business-wide ML/TF risk assessment, AML/CFT policies and procedures, customer acceptance and risk classification methodology, CDD/EDD processes, internal reporting and suspicious transaction escalation procedures, record-keeping requirements, governance and responsibilities, as well as the supporting forms and operational documentation required for effective implementation.

The objective is not simply to produce compliant documentation, but to build an AML/CFT framework that reflects how your organization actually operates and can be applied effectively in day-to-day activity.

Not every organization needs a formal independent AML/CFT audit, but every regulated business should know whether its compliance framework actually works.

I conduct a comprehensive review of your existing AML/CFT program, assessing its alignment with applicable regulatory requirements and the specific ML/TF risks of your business. The review covers key elements such as the business-wide risk assessment, internal policies and procedures, customer risk classification and CDD/EDD processes, transaction monitoring and reporting arrangements, governance, record-keeping and staff training.

The assessment identifies gaps, inconsistencies and areas where documented controls are not effectively implemented in practice. You receive clear, prioritized recommendations showing what needs to be corrected, strengthened or updated — without the scope and formality of a full independent AML/CFT audit.

I develop and conduct AML/CFT risk assessments tailored to your organization’s activities, business model and regulatory obligations. The assessment identifies and evaluates the ML/TF risks to which the organization is exposed, taking into account relevant risk factors such as customers, products and services, transactions, delivery channels and geographic exposure, in accordance with the risk-based approach required by Law no. 129/2019 and the applicable Romanian and EU AML/CFT framework.

Depending on your needs, I can develop the underlying risk assessment methodology, including risk factors, indicators, scoring criteria, weighting and risk classification rules, and apply it at both business-wide and customer level.
Existing methodologies and risk assessments can also be reviewed and updated to reflect changes in the business, regulatory requirements or identified risk exposure.

The result is a documented and practical risk-based framework that supports customer risk classification, the application of appropriate CDD/EDD measures and informed AML/CFT decision-making.

Romanian AML/CFT legislation requires certain reporting entities to ensure an independent audit function for testing the adequacy and effectiveness of their AML/CFT policies, internal rules, controls and risk management procedures. The applicability, scope and frequency of this requirement depend on the nature and size of the organization, as well as on the specific regulations or instructions issued by the competent supervisory authority or self-regulatory body.

I conduct independent AML/CFT audits in accordance with Law no. 129/2019 and the applicable sector-specific regulatory framework, taking into account the requirements and expectations of ONPCSB or, where relevant, other competent supervisory authorities and professional bodies.

The audit assesses both the design and practical implementation of the AML/CFT framework and may cover the business-wide risk assessment, policies and procedures, governance and responsibilities, customer risk assessment and CDD/EDD, transaction monitoring and reporting, record-keeping, training and internal controls. The scope and testing methodology are tailored to the organization’s activity, size, complexity and ML/TF risk exposure.

The engagement results in an independent AML/CFT audit report documenting the findings, identified deficiencies and areas for improvement, together with prioritized remediation recommendations. Where periodic independent audit is required by the applicable sectoral framework, the engagement can be structured accordingly to support ongoing compliance with that obligation.

I support organizations before, during and after AML/CFT inspections or supervisory reviews, helping them understand regulatory expectations, assess their level of preparedness and address identified compliance deficiencies. My previous experience in AML/CFT supervision and control provides me with a practical understanding of how compliance frameworks are assessed by supervisory authorities and where implementation weaknesses may arise.

Before an inspection, support may include a targeted review of the AML/CFT framework and documentation, identification of potential gaps, preparation of relevant records and evidence of implementation, and guidance for management, the designated person and other employees involved in the control process.

Following an inspection or supervisory action, I can assist with the analysis of findings and measures imposed, development of remediation plans, revision of policies, procedures and risk assessments, and implementation of corrective actions within the applicable deadlines.

Support is tailored to the applicable Romanian AML/CFT framework and, where relevant, to the regulations, instructions and supervisory requirements of ONPCSB or other competent sectoral authorities.

 AML/CFT compliance is an ongoing process, not a one-time exercise. I provide continuous advisory support to organizations that need specialized AML/CFT expertise without necessarily maintaining a dedicated in-house compliance function or expanding their existing compliance team.

I can act as your outsourced AML/CFT Compliance Officer, giving your organization direct access to senior-level expertise without the costs and administrative burden associated with recruiting and maintaining a permanent in-house position. Whether you need full-time or part-time support, the engagement can be tailored to the size and complexity of your business, its risk profile and the level of involvement required. This provides a flexible and cost-effective alternative for organizations that need experienced AML/CFT leadership without the commitment of a permanent hire.

Depending on the organization’s needs, ongoing support may include regulatory updates and impact assessments, review and update of policies, procedures and risk assessments, complex CDD/EDD cases and customer risk classification, PEP and sanctions matters, analysis of unusual or potentially suspicious activity, reporting obligations, staff training and preparation for regulatory inspections.

The scope of the engagement is tailored to your regulatory obligations, business model and internal resources, whether you need ongoing specialist advice, an outsourced compliance function or a combination of both.

I design and deliver AML/CFT training tailored to your organization’s activities, risk profile and the specific responsibilities of your employees. Training is designed to translate regulatory requirements into practical knowledge that staff can apply in their day-to-day work.

Depending on the audience and the organization’s needs, training may cover AML/CFT obligations, customer due diligence, identification of ML/TF risk factors and suspicious activity, internal escalation and reporting procedures, PEPs and sanctions, as well as industry-specific red flags and typologies. Dedicated training can also be provided for management, compliance personnel and the designated person.

Training content is aligned with the applicable requirements of Law no. 129/2019 and relevant ONPCSB regulations and guidance, and can be adapted to address regulatory changes, findings from internal reviews or audits, or specific weaknesses identified within the organization.