As a result of changes in the law, sanctions laid down for violations were tightened up as of 27 November 2017. The legislator also specified the substance of due diligence measures related to establishing and monitoring business relations. Under the amendments to the law, sanctions for finance-related violations (eg, violating the obligation to monitor a business relationship or to notify suspicion of money laundering and terrorist financing) will increase from EUR 32,000 to EUR 400,000. The Financial Supervision Authority suggested making local law comply with the IV Money Laundering Prevention Directive, under which the maximum sanction for a legal person is up to EUR 5 million or 10% of total annual turnover. However, this suggestion was declined.
The main reason for setting more severe sanctions is that previous legislation was too lenient and liberal in regard to not applying preventive measures. The purpose of revised sanctions is to motivate undertakings to refrain from committing infringements. Increasing financial sanctions does not automatically mean a dramatic increase in the amount of the fine imposed in practice. The purpose of raising fine rates was to enable more flexibility to the Financial Supervision Authority and the Financial Intelligence Unit in fulfilling their legal obligations.
