The recent amendments to the Regulation on the Program of Compliance with Obligations of Anti-Money Laundering and Combating the Financing of Terrorism (“Compliance Program Regulation“) made on 26 February 2021, entered into force on 1 May 2021. Changes included forming financial groups, appointing assistant compliance officers for financial institutions, organizing compliance programs and appointing compliance officers and assistant compliance officers at the group level. If you would like to learn more about the extent of the amendments, you can review our previous legal alert here. Along with the amendments, the Compliance Program Regulation also introduced deadlines. The obliged companies must determine the relevant additional obligations applicable to them and complete the necessary steps before the deadlines specified in the Compliance Program Regulation. You may find below the actions that need to be taken and the relevant deadlines for them, among others.
| No. | Actions | Relevant article | Deadline |
| 1 | Appointment of a compliance officer, as per Article 30 of the Compliance Program Regulation, by asset management companies. | Transitional Provision 1/4 | 1 June 2021 |
| 2 | Appointment of an assistant compliance officer who meets the qualifications specified under Article 17 of the Compliance Program Regulation, by the following institutions:
The qualifications for assistant compliance officers specified under Article 17 paragraph 1 subparagraph (d) of the Compliance Program Regulation will not apply until | Transitional Provision 1/5 | 1 June 2021 |
| 3 | Appointment of an assistant compliance officer by financial institutions that have already appointed a compliance officer as per Article 16 of the Compliance Program Regulation. The qualifications for assistant compliance officers specified under Article 17 paragraph 1 subparagraph (d) of the Compliance Program Regulation will not apply until | Transitional Provision 1/6 | 1 June 2021 |
| 4 | Appointment of a compliance officer and an assistant compliance officer by financial groups. The qualifications for assistant compliance officers specified under Article 17 paragraph 1 subparagraph (d) of the Compliance Program Regulation will not apply until | Transitional Provision 1/6 | 1 June 2021 |
| 5 | Informing the Financial Crimes Investigation Board Presidency regarding the legal nature of the financial group as explained under Article 3/A paragraph 3 of the Compliance Program Regulation. | Transitional Provision 4/1 | 1 June 2021 |
| 6 | Organization of a compliance program by the following financial institutions:
| Transitional Provision 1/5 | 1 July 2021 |
| 7 | Submission of the institution policy commitment form included in the Compliance Program Regulation annexes (ANNEX-1/A) to the Financial Crimes Investigation Board Presidency by the below listed financial institutions:
| Transitional Provision 4/2 | 1 July 2021 |
| 8 | Submission of the financial group institution policy commitment form included in the Compliance Program Regulation annexes (ANNEX-1/B) to the Financial Crimes Investigation Board Presidency. | Article 10/1 | Within 30 days following the confirmation of the financial group institution policy |
| 9 | Submission of the compliance officer and assistant compliance officer commitment form included in the Compliance Program Regulation annexes (ANNEX-2) to the Financial Crimes Investigation Board Presidency. | Article 16/4 | Within 10 days following the appointment |
