The Law on the Prevention of Money Laundering and Terrorism Financing (hereinafter referred to as: the Law) in Article 40 authorizes the Administration to issue a license for AML/CFT compliance officers and their deputies. The license is issued after a candidate has passed a technical exam. The content and the method of taking the exam is regulated by the Rulebook on Methodology for Implementing the AML/CFT Law.
The technical exam consists of a General and Specific Section. The General Section tests the knowledge of the Law and accompanying bylaws, whereas the Specific Section tests the knowledge of the AML/CFT system in the obligor-specific area. For example, the compliance officers in banks will be tested for the knowledge of the National Bank of Serbia Guidelines on Assessing the Risk of Money Laundering and Terrorism Financing, Recommendations for Reporting Suspicious Transactions, no Tipping Off and Customer Due Diligence, etc. The Specific Section may consist of a case study, where the candidate is expected, based on the given facts of the case, to put in writing a suspicious transaction report and explain reasons for suspicion. Please note that legal entities are required to have a license for each specific financial activity that they undertake. For example, if a bank also has a department for broker/dealer activities, as well as a department for insurance, the bank is required to have a licensed compliance officer for three different activities, namely – for banking, insurance and broker/dealer operations. It is irrelevant whether there will be three different compliance officers, or one person will have all three licenses.
Apart from the knowledge of relevant legislation, the candidates are expected to have a proper understanding of how the system has been established and how it should ideally work.
The technical exam is taken before a three-member Examination Panel, established by the Administration Director. The Examination Panel decides on the results of the exam by a majority vote.
A successful candidate will have scored more than 80 % of points and will have the license issued. The license is issued for the period of five years.
A candidate who has scored less than 80% of points is considered to have failed the technical exam, and is allowed to take it again two months following the failed exam.