Short answer
What foreign companies call an "AML audit" is, from a law office, a legal review: we compare your existing procedures, records and reports with the obligations under Law 129/2019 and point out gaps in writing. It is not a statutory financial audit and it is not a check carried out by an authority.
What the legal review looks at
Scope
Whether the company was correctly classified as a reporting entity, or not, under art. 5 of Law 129/2019.
Customer due diligence
Whether written due diligence and record-keeping procedures exist and match what the law and secondary rules require.
Reporting to ONPCSB
Whether the internal process identifies the reports that apply (suspicious, cash from EUR 10,000, external transfers for financial institutions) and uses the approved forms.
Beneficial owner
Whether the beneficial owner declaration at the Trade Register reflects the current ownership (art. 56).
Documents usually requested
- Trade Register extract and articles of association
- Current AML policy and internal procedures
- Templates used for customer identification and due diligence
- Internal reporting and record-keeping rules
- The latest beneficial owner declaration
The result is a written list of findings and suggested corrections; it does not certify compliance and cannot replace the supervision carried out by the competent authority.
Related pages
- AML compliance in Romania — the legal obligations under Law 129/2019
- AML services in Romania
- AML advisory in Romania
- UBO declaration in Romania
General legal information, not legal advice. Each situation requires individual review. Cabinet de Avocatură Pantilimon Rikhárd-Árpád, based in Târgu Mureș.