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.

Sanijel Ficulovic joins PFR as attorney

We congratulate Sanijel Ficulovic on his appointment as attorney! With his entry, PFR strengthens the Banking & Finance team around partner Bernd Fletzberger.

Sanijel Ficulovic has comprehensive experience in solving regulatory issues in banking, e-money and payment services law. At PFR, Sanijel Ficulovic specialised in legal advice for new business models, the implementation of regulatory requirements, money laundering compliance and supporting financial services providers in defending against administrative fines. In addition, his focus is on innovative business models and technologies, in particular in the field of crypto assets and blockchain.

Sanijel Ficulovic (31) has been an integral part of PFR's Banking & Finance team since 2018. He was admitted to the bar in January 2022 and worked as a trainee lawyer in a renowned international business law firm in Vienna before joining us. Sanijel Ficulovic emphasises: "During my time at PFR, I learned a lot about how to best serve clients, both professionally and personally, and was able to benefit greatly from the firm's broad positioning. I am pleased and proud to be able to continue my practice as a lawyer in this outstanding team."

"We are extremely pleased to welcome Sanijel to our firm as an attorney. With his admission as attorney-at-law, PFR continues its growth and will be able to advise clients from the financial sector even more comprehensively in all areas of financial market law in the future," PFR partner Bernd Fletzberger says delightedly.


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