The Anti-Money Laundering Authority Reporting Guidelines for Financial Assets Service Providers and Credit Service Providers
14 November 2021
Dear Clients and Colleagues,
On October 20, 2021, Israel’s Money Laundering and Terror Financing Prohibition Authority (“IMPA”) published its reporting guidelines for Financial Asset Service Providers and Credit Service Providers (the “New Reporting Guidelines”).
The New Reporting Guidelines were published as a complementary step to the Prohibition of Money Laundering (Identification, Reporting and Recordkeeping Duties of Financial Asset Service Providers and Credit Service Providers for the Prevention of Money Laundering and Terrorism Financing) Order, 5778-2018, which came into effect (in general) on November 14, 2021 (the “New Order”).[1] The New Order imposes obligations under the anti-money laundering and terror financing regime on Financial Assets Service Providers, and updates some of the provisions that apply to Credit Service Providers.
The New Order includes, inter alia, an obligation to report to IMPA transactions above certain amounts as provided in the Order (ordinary transaction), as well as any action/transaction (or attempted transaction) that is deemed unusual by the Financial Service Provider. The New Reporting Guidelines outline the format for submitting these reports, and the reporting deadline.
In accordance with the New Reporting Guidelines, the reports to IMPA on ordinary and unusual transactions will be made through IMPA’s secured online reporting site, the Odem System. Please note that using the system requires prior arrangement and registration. For additional information and the procedure for connecting to the online reporting site Click here (Hebrew).
A report regarding an ordinary transaction is required to be submitted to IMPA no later than the 7th of the month following the month to which the report relates. A report regarding an unusual transaction (including an attempt to perform such a transaction) is required to be submitted to IMPA as soon as possible in the circumstances of the case, after the transaction has been performed or registered, as applicable.
In general, the New Reporting Guidelines will take effect on 31.12.2021 (except for Financial Service Providers who have notified the Capital Market Authority that they are applying the provisions of the New Order at an earlier date).
For IMPA’s publication and the New Reporting Guidelines Click here (Hebrew)
Please note that IMPA has published a reference file on its website to illustrate the ordinary reporting according to the New Reporting Guidelines, as well as a form for reporting unusual transactions in accordance with the Guidelines. IMPA has also recently published a document aimed at preventing a failure in the process of receiving files related to the reports mentioned above. For these publications, please see the following link to the relevant page on IMPA’s website Click here (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.
We will be happy to advise and assist with any questions on the subject.
Herzog Fox & Neeman
Ayelet Regavim Kahanov | Partner
[1] The terms Financial Asset Service Providers and Credit Service Providers are as defined under the applicable AML order.
