Anti-Money Laundering Authority reporting guidelines for financial asset service providers and credit service providers

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On October 20, 2021, the Israel Money Laundering and Terrorist Financing Prohibition Authority (“IMPA”) released its reporting guidelines for financial asset service providers and credit service providers ( the “new reporting guidelines”).

The new reporting guidelines were issued as a complementary step to the Money Laundering Prohibition Order (identification, reporting and record keeping obligations of financial asset service providers and suppliers Credit Services for the Prevention of Money Laundering and Terrorist Financing), 5778-2018, which came into effect (generally) on November 14, 2021 (the “New Order”).[1] The new ordinance imposes obligations under the anti-money laundering and terrorist financing regime on providers of financial asset services, and updates some of the provisions that apply to providers of credit services.

The New Order includes, among other things, an obligation to report to IMPA transactions greater than certain amounts as provided for in the Order (ordinary transaction), as well as any action / transaction (or attempted transaction) deemed unusual by the Service Provider. of financial services. The new reporting guidelines describe the format for submitting such reports and the reporting deadline.

In accordance with the new reporting guidelines, reporting to IMPA on ordinary and unusual transactions will be made through IMPA’s secure online reporting site, the Odem system. Please note that use of the system requires prior arrangement and registration. For more information and how to log into the online reporting site Click here (in Hebrew).

A declaration concerning an ordinary transaction must be submitted to IMPA no later than the 7th of the month following the month to which the declaration relates. A report regarding an unusual transaction (including an attempt to effect such a transaction) should be submitted to IMPA as soon as possible in the circumstances of the case, after the transaction has been completed or recorded, as applicable.

In general, the new reporting guidelines will come into force on 12.31.2021 (except for financial service providers who have notified the Capital Markets Authority that they are applying the provisions of the new ordinance at an earlier date).

For the IMPA publication and new reporting guidelines, click here (in Hebrew)

Please note that IMPA has published a reference file on its website to illustrate ordinary reporting according to the New Reporting Guidelines, as well as a form for reporting unusual transactions according to the Guidelines. IMPA also recently published a document aimed at preventing a failure in the process of receiving files related to the above-mentioned reports. For these publications, please see the following link to the corresponding page on the IMPA website. Click here (in Hebrew).

The above summary does not set out all of the instructions and requirements specified in the publications mentioned in this update, and we recommend that any interested party read these publications carefully.


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