The situation
A description of a planned business model in two countries
Your company in Stockholm runs an invoicing platform for small firms. Next year it wants to buy invoices from those firms at a discount, and to launch the same service in Bucharest through a Romanian subsidiary. The investors have asked whether this makes the company an obligated entity under anti-money-laundering law, and what that would take to run.
The definitions sit in the directive and its national transpositions. The hours go on fitting a new business model to them, checking what each national law adds, reading what the regulators have published and working out which supervisor the company would answer to. The note has to be clear enough for a board decision.
What the research has to settle
The rules behind the answer
- Status follows the activity
- Obligated entities are defined by what they do. Financial institutions are in scope, and they include undertakings whose activities include lending, which in the EU definition covers factoring. Buying invoices from customers is therefore likely to bring the company in.
- National law can widen the circle
- Member states may extend the rules to further types of business. Sweden and Romania each list obligated entities in their own AML acts, and today it is the national list that applies.
- Being in scope brings a set of duties
- An obligated entity carries out a business-wide risk assessment, applies customer due diligence, reports suspicious transactions to the financial intelligence unit, trains staff and appoints a responsible person. National law may also require registration before the business starts.
- The EU rulebook is changing
- The new Anti-Money Laundering Regulation applies directly from July 2027 and harmonises the list of obligated entities. A business launching now should check both the national law in force and the Regulation.
How it runs in azta
From the question to the document
The question, as you would type it
Swedish invoicing platform plans to buy SME invoices at a discount in Sweden and, through a subsidiary, in Romania. Does this make us an obligated entity under Swedish and Romanian AML law, who would supervise us, and what have Finansinspektionen and ONPCSB published that applies?
You start with
A description of a planned business model in two countries
- 01
Describe the business model
Set out what the company will do in each country and for whom. azta searches the EU AML rules, the Swedish and Romanian AML acts, and the material it holds from Finansinspektionen, ONPCSB and ASF.
Cited research· Free - 02
Read the national lists in full
Open the Swedish and Romanian provisions on obligated entities in the statute reader, in the original language, with their in-force status.
Atlas statute reader - 03
Draft the board note
Ask for a note that answers the status question per country, names the likely supervisor and lists the duties that follow. Edit it in Canvas.
Canvas · Ask azta· Pro - 04
Export for the board pack
Export to Word and keep the cited research for the compliance file.
Word export· Pro You send
A board note on obligated-entity status, supervisor and the duties that follow
What you get
A board note on obligated-entity status, supervisor and the duties that follow
Board note · draft
AML status of the invoice-purchasing service
Conclusion. Buying invoices is a lending activity within the definition of a financial institution. On the sources reviewed, the Swedish company and the Romanian subsidiary would each become obligated entities when the service starts, and should plan for it now.
Sweden. The company would need to meet the AML duties and the registration requirement identified in section 2, under Finansinspektionen’s supervision. The regulator material cited in Annex A sets out what it expects of the risk assessment and customer due diligence.
Romania. The subsidiary would fall under the Romanian AML act. Which authority supervises it depends on its licensing status and is set out in section 3, with the ONPCSB material on reporting. Running both entities would need a responsible officer in each and a group-wide policy.
Outcomes on your numbers
What azta is worth on this task
Pro pays for itself after
15 minutes a month
At €110 an hour, that is all the time Pro (€27 a month) has to take off your desk to cover its price.
Example figures. Replace them with your own.
- Hours back a year
- 22
- Capacity at your rate
- €2,376
- More AML status notes a quarter
- 0.7
- Return on Pro
- 7.3×
- Research
- Drafting
- Your review
A scenario you set, not a promise. The hours that come back go to another client, or deeper into this one.
Want these numbers on your team’s real workload?
Book a demoSources azta searches here
- Riksdagen (SFS)
- Finansinspektionen
- legislatie.just.ro
- ONPCSB
- EUR-Lex · Curia
What stays with you
- The business model and how it may change before launch.
- Licensing questions and any approach to the regulators.
- The board decision and the compliance budget.
Frequently asked questions
- Which regulators’ material does azta hold here?
- For this question, Sweden’s Finansinspektionen and Romania’s ONPCSB and ASF. For most other countries azta holds legislation and case law, not regulator material.
- Does it cover the new EU AML package?
- Yes. EU law is in the corpus, including the new Regulation. Ask about the date you need and azta cites the rules in force then.
- Can it write our AML policy?
- It can draft one in Canvas from the cited duties. The risk assessment behind it is your judgement, and the policy needs your sign-off.
