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.

Question 7

Client due diligence: what a complete file should contain

Accepted Answer

Client due diligence is the operating core of AML: know who the client is, understand what they want you to do, identify the people who control them, screen the relevant parties and record a risk-based decision before acting.

Question 8

Enhanced due diligence: when ordinary CDD is not enough

Accepted Answer

Enhanced due diligence is not a punishment; it is the documented extra work an office performs when a relationship or matter carries higher AML risk. The point is to understand risk well enough for a senior person to accept, mitigate or refuse it.

Question 9

Source of funds versus source of wealth

Accepted Answer

Source of funds and source of wealth are related but different questions. Source of funds explains the specific money used in the matter. Source of wealth explains how the client or UBO accumulated their overall wealth.

Question 10

Adverse media screening: what negative news should trigger

Accepted Answer

Adverse media screening helps an office identify public information that may indicate predicate offences, sanctions evasion, corruption, fraud, terrorism financing or other AML-relevant risk. It is an input into judgment, not an automatic decision.

Question 11

Ongoing monitoring and periodic reviews

Accepted Answer

AML obligations continue after acceptance. Clients change, ownership changes, sanctions lists change, matters expand and risk indicators appear after the first onboarding decision. Ongoing monitoring is the control that catches those changes.

Question 12

AML inspection pack: what to prepare before a supervisor asks

Accepted Answer

An AML inspection pack is the structured evidence package that lets an office show how its compliance system works in practice. It should connect policies, business-wide risk assessment, training, client files, decisions, reports and remediation into one coherent story.

Question 13

Compliance as a Service: what can be outsourced and what cannot

Accepted Answer

Compliance as a Service is useful only if the boundary is honest. An office can ask specialists and software to run much of the AML machinery, but it cannot outsource its legal status, professional judgment or official accountability.

Question 14

goAML filing preparation: from suspicion narrative to submit-ready package

Accepted Answer

Since CTIF-CFI moved suspicious transaction reporting to goAML, the practical burden is no longer just deciding whether to report. Offices also need clean facts, a structured suspicion narrative, supporting evidence, restricted access and proof of what was submitted or why no report was made.

Question 15

AML for lawyers: privilege, scope and the Bar-filter route

Accepted Answer

Lawyer AML is different because the compliance workflow must respect professional secrecy, legal privilege and the Bar’s filtering role. A generic AML file is not enough where privileged legal analysis and regulated transactional assistance may sit close together.

Question 16

UBO discrepancies: what to do when declaration, register and evidence disagree

Accepted Answer

UBO work is not finished when a client fills in a form. The office must understand who ultimately owns or controls the client, compare declarations against evidence, and handle discrepancies instead of burying them in the file.

Question 17

Cash payment limits: turning a legal rule into an active file control

Accepted Answer

Cash restrictions are simple on paper and surprisingly easy to miss in practice. The risk appears at the moment a payment method, deposit, advance, commission or settlement route is discussed, not at the end of the file.

Question 18

AI-assisted AML compliance: useful help, not an automated legal decision

Accepted Answer

AI can make AML work faster, but it should not become the invisible decision-maker. The safest pattern is assistive AI: document read-back, case summaries, draft narratives, alert explanations and checklist suggestions, all clearly labelled and subject to human review.

Question 19

GDPR accountability: what an office actually needs to prove

Accepted Answer

GDPR accountability means being able to show how personal data is processed, why it is lawful, who receives it, how long it is kept, how risks are controlled and what evidence supports each conclusion.

Question 20

ROPA records: how to make Article 30 practical

Accepted Answer

A record of processing activities is the map of how an organization processes personal data. It should explain the purpose, categories of people and data, lawful basis, recipients, systems, retention, transfers and safeguards.

Question 21

Data subject requests: deadlines, identity checks and evidence

Accepted Answer

Data subject requests are operationally awkward because they combine legal judgment, identity verification, deadlines, document search, exemptions and careful communication.

Question 22

Personal-data breaches: the 72-hour clock and the evidence trail

Accepted Answer

A personal-data breach is not only a cybersecurity event. It can be a misdirected email, lost device, wrong portal access, exposed file, ransomware incident or accidental disclosure.

Question 23

DAC6 arrangement register: hallmarks, deadlines and filing evidence

Accepted Answer

DAC6 is not just a question of whether a hallmark appears. The office needs to understand whether there is a cross-border arrangement, who has the reporting role, whether privilege affects the route, which hallmark applies, whether the main-benefit test matters and when the deadline runs.

Question 24

CRS/FATCA self-certification: when evidence mode is enough and filing mode is not

Accepted Answer

CRS and FATCA do not apply in the same way to every professional office. Filing obligations sit with Reporting Financial Institutions and related reporting roles; many advisors only need evidence-support workflows for client tax-residency information.

Question 25

Whistleblowing channels: confidentiality, deadlines and case handling

Accepted Answer

A whistleblowing channel is not just a mailbox. It is a controlled process for receiving reports, protecting confidentiality, assigning handlers, acknowledging receipt, giving feedback and documenting the outcome.

Question 26

Professional conflict checks: from name search to decision record

Accepted Answer

Conflict checks are often treated as a quick name search. That misses the point. A professional conflict workflow should identify the matter, parties, related entities, former clients, adverse interests, confidential-information risk and any consent or ethical-wall decision.

Question 27

Client-money control: matter sub-ledgers, release approvals and reconciliation

Accepted Answer

Client money creates a different kind of risk: the office is holding funds that belong to someone else or are tied to a specific matter. That demands segregation, matter-level records, release approvals, reconciliation and evidence.

Question 28

Provable compliance: ledger proofs, replay and inspector access

Accepted Answer

Compliance is stronger when it can be verified independently. A file should not only say that screening, review or sign-off happened; it should let a reviewer verify the evidence chain and reproduce deterministic decisions from the recorded inputs and versions.

Question 29

Real-estate AML under AMLR: sales, lettings and developers

Accepted Answer

Real-estate AML work should follow the transaction, not just one client record. When a sale or qualifying letting is in scope, the office has to understand both sides, the property, the payment route and the timing of verification.

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