New EBA Guidelines regarding AML Officer


The European Banking Authority (EBA) published Guidelines on policies and procedures for compliance management and the role and responsibilities of the Anti-Money Laundering Officer (AML Officer) on 14th June 2022.

These will come into force on 1st December 2022 and apply to all financial sector entities falling within the scope of the Anti-Money Laundering Directive (AMLD). In this post, we have summarized the main changes for the AML officers and the responsible management bodies based on the Guidelines.

Updated FMA circulars regarding the prevention of money laundering and combat of terrorist financing


On February 23, 2022, the Austrian Financial Market Authority (FMA) published updated circulars regarding the prevention of money laundering and combat of terrorist financing (ML/TF). These changes affect all four circulars, namely the circulars on Due Diligence Obligations, Risk Analysis, Internal Organisation, and Reporting Obligations.

This article summarises the main changes of the updates. It intends to assist obliged entities to quickly identify whether and to what extend their internal policies need to be amended.

Non Fungible Tokens (NFT) - Legal Issues in Sale and Purchase


Non Fungible Tokens (NFTs) have attracted a lot of attention in recent months due to the sale of artworks at record high prices, for example Beeples "Everydays" for USD 69 million.

In Austria, NFTs are increasingly being used as a marketing tool. For example, the Ströck bakery raffled off thirty limited edition doughnut ("Krapfen") NFTs on Carneval Tuesday. Another example is the launch on 3 March 2022 by the Austrian Football Association of an NFT collection with motifs of national soccer players.

Of course, you can't eat NFT doughnuts and the NFT soccer pictures can't easily be stuck into a scrapbook either. Therefore the question arises what makes NFTs so valuable.

This article attempts to provide some answers and explains legal issues to consider when selling or buying NFTs.

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