Supervision process

The APML carries out offsite and onsite AML/CFT supervision of factoring companies and accountants as set out in Articles 106 – 108 of the AML/CFT Law.

Offsite supervision involves collection of information from factoring companies and accountants about whether they are complying with the AML/CFT requirements and how, and then APML analyses this information in order to take further action.

Onsite supervision is carried out on the supervised entity’s premises or on those of the company that is indirectly or directly related to the supervised entity. APML inspectors inspect internal policies and procedures, records and documentation, and the business books, and selected accounts, correspondence and other documents. Inspectors can take statements from the responsible persons and other supervised entity’s employees. For the purpose of supervision, the APML can request information from other state authorities and from its foreign counterparts.

APML applies the risk-based approach (RBA) to supervision. This means that it will make an appropriate prioritisation of obliged entities that are found to be more exposed to the ML/TF risk in performing their registered business, when preparing its annual Inspection Plan.