The State Tax Service requires Obliged Parties to implement an Internal Control Program to comply with the AML/CFT Law. You must submit proof of the following actions by October 1, 2025:

• Prepare Internal Rules: Draft the necessary internal rules and procedures that meet the “Minimum Requirements to be Met by the Internal Control Program of Obliged Entities.”
• Designate a Responsible Person: Officially identify a responsible person at the management level for the internal control program, along with a designated replacement.
• Submit Information: Provide documentation to the State Tax Service confirming the establishment of these rules and the identification of the responsible personnel.

Obliged Parties must secure registration in the Financial Monitoring Service’s new electronic reporting platform: the Suspicious Operations Monitoring System (SAMS – ŞƏMS).

• System Access: Obliged Parties must register in SAMS using their ASAN Imza (mobile e-signature).
• Purpose: SAMS is the mandatory electronic software for submitting all required information and documents to the Financial Monitoring Service (FMS).

The Law requires prompt reporting of specific information and documents to the FMS:

• Standard Reporting: Information regarding certain carried-out transactions must be submitted to the FMS within 3 working days after the operation occurs.
• Immediate Reporting: In cases involving potential suspicions, the information and documents must be submitted immediately after the basis for suspicion is determined, and no later than the end of that business day.

Failure to fulfill these requirements constitutes a violation of the Law and may lead to liability under Article 598 of the Code of Administrative Offences.

The penalties are severe:

• Officials face fines from AZN 800 to AZN 1,500.
• Legal Entities face substantial fines from AZN 8,000 to AZN 15,000.