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Showing posts with the label MLRO

MiCA-Compliant AML Governance: From Policy to Practice

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As the Markets in Crypto-Assets Regulation (MiCA) enters into force, crypto-asset service providers (CASPs) must move beyond checkbox compliance. European regulators now demand that AML/CFT systems reflect operational reality — not just policy templates. In particular, in the Czech Republic, where CASPs were previously governed under Act №253/2008 Coll., the shift to MiCA introduces stricter expectations around governance, independence, and internal control.  AML Governance Under MiCA: Structural Expectations: MiCA requires that firms implement robust internal governance and control mechanisms (Article 63), including:  A clear three-lines-of-defense model;  An independent Money Laundering Reporting Officer (MLRO); A Board-level oversight function;  A dedicated compliance function with the authority to act licensing and regulatory liaison process to ensure ongoing conformity with MiCA and TFR.  At Artlex Consult, we have designed a MiCA-aligned AML structure that...

Why Every Obliged Entity Needs an Experienced MLRO and MLCO: The Czech AML/CFT Law Perspective

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  Mgr. Hovsep Kocharyan, Ph.D. Mgr. Lusine Vardanyan, Ph.D. 1. Introduction Currently, in the context of a dynamically developing regulatory framework, compliance with all applicable AML/CFT standards, guidelines and requirements is a strategic necessity. In accordance with the Czech Anti-Money Laundering Act No. 253/2008 Coll. (referred to as the “Czech AML Act”), every obliged entity must implement comprehensive, detailed, proportionate and effective AML/CFT (anti-money laundering and terrorist financing) policies, procedures, measures, and controls.  The Czech AML landscape is changing fast. MiCA, DORA, AMLA Regulations  — all raise the stakes for fintech and crypto firms. This article explores why, in light of evolving EU regulations, it is now more critical than ever for obliged entities, including primarily for CASPs, Payment Service Providers (PSPs), Banks, Investment Firms, and Electronic Money Institutions (EMIs) to have a dedicated and experienced AML/CFT C...