Commercial accounts and operational companies: which specific AML monitoring is expected?

What specific kind of monitoring is expected for this type of business relationship: identification of related parties, counterparties, internal organization, etc.?
How to verify the reality of intra-group transactions? How to detect predicate offenses to ML?

Operational companies, domiciliary companies and holdings

• What distinguishes operative companies from domiciliary companies?
• How should companies without staff or offices be classified? Which criteria of economic presence are decisive for categorization?
• How do holding structures (pure, management, mixed) differ, and what are their implications for the management of subsidiaries?
• What disclosure obligations and forms are relevant in practice?
• How does company classification affect compliance obligations? How does classification intersect with anti-money laundering obligations?

AML life cycle management for commercial accounts/commercial companies

• Specificities of KYC, KYT, SOW (Source of Wealth), SOF (Source of Funds)
• KYC, onboarding
• Monitoring of commercial transactions
• Periodic reviews, consideration of sanctions regimes

Compliance management of commercial/operational groups

• What specific monitoring is expected for this type of business relationship (identification of related parties, counterparties, internal organization, etc.)?
• How to ensure effective monitoring of commercial accounts and what internal expertise is required (accounting, tax, financial, etc.)?
• How to verify the reality of intra-group transactions and detect predicate offenses to money laundering?
• Focus on specific transactions:
• Intra-group loans: key points, documentation, corroboration, follow-up
• Dividend distributions: red flags, documentation, corroboration
• Intra-group service provision: transfer pricing and tax optimization issues

Should counterparty relationships be monitored? And how can this be done?

• What types of relationships should be identified (family, business, etc.) and how should this link be recorded in the file/system?
• What monitoring and oversight are expected between counterparties?

Preparatory work required to apply trade sanctions

• Screening and verification of partners
• Implement screening tools to check clients, suppliers, and partners against sanctions lists
• Carry out enhanced due diligence for high-risk areas or sensitive products (dual-use goods, advanced technologies)
• Documentation and traceability
• Keep comprehensive documentation of transactions and verifications performed
• Risk assessment
• Identify geographic areas, products, or clients exposed to sanctions risks
• Adapt commercial strategies to avoid inadvertent violations
• Specific contractual clauses
• Include non-re-exportation or sanctions-compliance clauses in contracts
• Provide for termination mechanisms in case of sanctions violations