For the purposes of the AML Act, the following are considered as service providers: financial service providers, entities engaged in real estate transactions, accountants, auditors, attorneys, tax experts and notaries, gambling service providers, precious metal and commodity traders, fiduciaries, art and antique dealers, and registered office service providers (this list is not exhaustive). Under the draft amendment, the National Risk Assessment (which shall be prepared and continuously reviewed by every Member State pursuant to an EU directive) must be capable of identifying, assessing, interpreting, and continuously reviewing the risks associated with not only money-laundering and financing of terrorism, but the financing of proliferation, too (i.e. facilitating the illegal spreading of weapons of mass destruction).
The amendment stipulates that service providers shall conduct a risk assessment before the introduction of a new business practice, product or technology, provided that the service provider is required to conduct an internal risk assessment (for example, service providers subject to supervision by the Hungarian National Bank or the Office for Combating Money Laundering and Terrorist Financing of the National Tax and Customs Administration).
The amendment also includes provisions regarding the transit of cash (i.e. currency, bearer-negotiable instruments, commodities used as highly liquid stores of value, or prepaid cards) across the border between Hungary and other EU Member States: any person intending to carry cash across the border is required to notify the cash transit control authority of their intention to transport or bring in cash in an amount of EUR 10,000 or more, and to present proof of such notification upon request by the authority. If the cash carrier fails to comply with this request, the authority will seize the cash.