On 14 March 2025, the amended AML/CFT Law entered into force.
The amendments were aimed at ensuring full compliance with the requirements of the European Union in the field of preventing money laundering and financing of terrorism (the Fifth EU Directive) and FATF recommendations relating to risk assessment and the application of a risk-based approach, international cooperation, as well as new technologies (i.e. VA/VASP).
The most significant amendments include introduction of new obliged entities who will be required to perform CDD, including identifying and verifying client identity, beneficial owners, etc. Among the new obliged entities are trust or company service providers, persons engaged in the business of trading, organizing and conducting auctions of works of art, precious metals and precious stones, as well as the business of storing and keeping, trading and brokering works of art if payments are made or received in the amount of the RSD equivalent of EUR 10,000 or more, regardless of whether this is done in one or more related transactions.
Furthermore, these amendments have brought the sanctioning policy into line with European standards and the requirements of the Fifth EU Directive in this area, as well as with the provisions relating to the relevant circumstances taken into account when imposing penalties and measures, the publication of imposed penalties and measures, the procedure for deciding on fines and measures by supervisory authorities, as well as the possibility of using legal remedies against decisions issued by supervisory authorities on fines and measures.
Also, the amendments also specify in more detail the provisions transposing the requirements of the Fifth EU Directive in relation to the protection of obliged entity staff who report breaches of the AML/CFT Law or suffer harmful actions due to the application of this law, the exchange of information between FIUs, as well as the data retention periods for data, information and documentation collected under this law.