AML / KYC Compliance in Albania

Anti-money-laundering obligations in Albania reach well beyond banks. Financial institutions, fintech operators and a range of non-financial businesses and professions may qualify as obliged entities, each with duties around customer due diligence, record-keeping, internal controls and the reporting of suspicious activity.

Andoni Law & Tax advises obliged entities and their management on how Albanian AML/KYC requirements apply to their activity and how to implement them in practice. Reporting and oversight functions in this area involve, among others, the General Directorate for the Prevention of Money Laundering — the Albanian financial intelligence unit — alongside sector supervisors such as the Bank of Albania.

Our focus is practical compliance: policies that match the business, due diligence procedures that staff can actually follow, and documentation that stands up when a supervisor reviews it.

What This Service Covers

We assist banks, financial institutions, fintech and crypto operators, and non-financial obliged entities with the legal side of AML/KYC compliance. Typical work includes:

• assessment of whether and how Albanian AML obligations apply to a specific business
• drafting and updating AML/KYC policies, procedures and internal control documents
• design and review of customer due diligence and enhanced due diligence frameworks
• advice on beneficial ownership identification and record-keeping duties
• guidance on suspicious activity reporting processes and internal escalation
• support in responding to requests, inspections or findings from supervisors

When This Service Is Appropriate

AML/KYC legal support is typically needed in situations such as:

• setting up a bank account, licence application or partnership that requires an AML framework
• launching a fintech, payment or digital-asset service subject to AML duties
• onboarding higher-risk customers or entering higher-risk markets
• receiving an inspection notice, information request or finding from a supervisor
• remediating gaps identified by an audit, a bank or a counterparty

Why Legal Support Matters

AML compliance failures carry consequences on several fronts at once: supervisory measures and possible sanctions, strained banking relationships, and reputational damage that is difficult to reverse. In many cases the underlying problem is not bad intent but policies copied from templates that do not match how the business actually operates.

The obligations are also risk-based, which means the law expects each entity to calibrate its controls to its own customers, products and exposure. That calibration is a judgment call — and one that should be documented, because supervisors typically assess not only whether controls exist but whether they are reasoned and applied.

Legal support helps translate the requirements into a framework that fits the specific business: obligations are identified correctly, procedures are proportionate and workable, and the entity can explain its approach when asked.

How We Work

1. We assess the obligations

We review the entity's activity, customers and structure to determine which Albanian AML/KYC requirements apply and where the main exposure lies.

2. We review or build the framework

We examine existing policies and procedures — or draft them where missing — covering due diligence, beneficial ownership, record-keeping, monitoring and reporting, adapted to the entity's risk profile.

3. We support implementation

We assist with the practical rollout: internal responsibilities, escalation lines, documentation standards and coordination with compliance staff, including guidance materials where useful.

4. We respond when issues arise

If a supervisory request, inspection or finding arrives, we review the file, help prepare the response and advise on remediation steps before submission.

Frequently Asked Questions

Who is subject to AML obligations in Albania?

Banks and financial institutions are covered, and Albanian law also extends AML obligations to various non-financial businesses and professions. Whether a specific business qualifies depends on its activity and should be verified case by case.

Which authority receives suspicious activity reports in Albania?

Reporting in this area involves the General Directorate for the Prevention of Money Laundering, which acts as the Albanian financial intelligence unit, while sector supervisors such as the Bank of Albania oversee compliance within their remit.

Can you draft our AML/KYC policies and procedures?

Yes. We prepare or update AML/KYC policies, due diligence procedures and internal control documents, adapted to the entity's activity and risk profile.

Do fintech and crypto businesses have AML duties in Albania?

Operators carrying out covered activities are generally subject to AML/KYC requirements. The precise obligations depend on how the activity is classified under the applicable framework.

Can you assist after a supervisory finding or penalty?

Yes. We review the finding, the legal basis and the applicable deadlines, and advise on the available response and remediation options after examining the file.

Need Help With AML / KYC Compliance in Albania?

Contact Andoni Law & Tax to assess your obligations, review or build your AML/KYC framework, and prepare documentation that stands up to supervisory review in Albania.

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