The AML designated person and reporting to ONPCSB

The statutory obligation, level of designation, internal instrument and any notifications or registrations required by the supervisory authority must be checked. Not all companies and not all roles are subject to the same regime.

The mandate must provide for access to information, management and systems, confidentiality protection, resources and the absence of incompatible conflicts. Management retains its own supervisory responsibilities.

• designation instrument and role description;
• direct reporting line;
• access to files and transactions;
• escalation and decision-making procedure;
• deputy and continuity plan.

Teams must know which indicators to report, through which channel and what information to attach. The designated person documents the analysis, requests clarification and decides on the next step in accordance with the procedure and the law.

Access to sensitive files must be restricted. Communications to the client and other teams must be controlled so that the investigation and confidentiality obligations are not compromised.

The reports provided for by Law No. 129/2019 are submitted in the cases and within the deadlines prescribed by law, electronically through the ONPCSB portal, in accordance with the requirements in force. Accounts, certificates, contact details and access rights must be kept operational.

The procedure must distinguish report types, deadlines and situations that may require immediate measures. Registration numbers, confirmations and supporting documents must be retained under controlled conditions.

Leave, termination of employment or technical unavailability must not block reporting. A deputy, access rules, documented handover and prompt revocation of previous access rights are required.

Performance indicators for the function may track outstanding alerts, analysis times, expired KYC files, training and control remediation, without turning the number of reports into a commercial target.