The National Bank of Moldova has published a draft decision to amend its anti money laundering and counter terrorist financing rules for banks and non bank payment service providers. The draft would transpose Commission Delegated Regulation (EU) 2019/758 and set minimum actions and additional measures for firms with branches or majority owned subsidiaries in other states where local law prevents full application of group wide AML and CFT policies. For each host state, affected firms would have to assess and document group exposure to money laundering and terrorist financing risk, reflect that risk in group policies, obtain senior management approval and provide targeted staff training. Where host country law restricts customer due diligence, intra group sharing or processing of customer data, sharing of suspicious transaction information, transfers of customer data to the National Bank of Moldova for AML supervision, or equivalent record keeping, firms would have to notify the central bank within 28 calendar days, seek client or beneficial owner consent where legally possible, and apply risk based additional measures. Those measures include limiting products and services, requiring fresh customer due diligence by other group entities, conducting consolidated reviews or on site audits, escalating higher risk relationships for senior management approval, identifying source and destination of funds, strengthening ongoing monitoring, and ensuring systems for suspicious transaction reporting. If the risk still cannot be managed effectively, the branch or subsidiary would have to stop the relationship or transaction and close part or all of its operations in that state. The draft states that the amendments would enter into force three months after publication in the Official Journal of the Republic of Moldova.