Name
Global FinTech Guide
Country _ Name
North Macedonia
SectionTitle
KYC requirements
Body
The know your customer or know your client (KYC) guidelines and regulations for financial services require that professionals try to verify the identity, suitability, and risks involved with maintaining a business relationship.

Legal affairs

National regulatory framework regarding AML and effective date of the regulations

The AML and CTF Law, regulates the measures, activities, and procedures that the entities and the competent bodies take for detecting and preventing money laundering, connected crimes, and financing of terrorism, as well as the operation and the competence of the Financial Intelligence Office (Office).

The AML and CTF Law was adopted in 2022 (“Official Gazette of the Republic of North Macedonia” nos. 151/2022; 208/2024 and 59/2025) and is harmonized with the EU Directive 2018/843 of the European Parliament and of the Council on the Prevention of the Use of the Financial System for the Purposes of Money Laundering and Terrorist Financing from 2018, amending EU Directive 2015/849 of the European Parliament and of the Council on the Prevention of the Use of the Financial System for the Purposes of Money Laundering and Terrorist Financing from 2015.

National regulator or relevant authority for AML controls

The Office is a state administrative body within the Ministry of Finance, a unit of financial intelligence of the Republic of North Macedonia that oversees the implementation of the anti-money laundering and terrorist financing legislation. The Office is empowered to collect, process, and provide information, and to impose fines on entities that are responsible for implementing know-your-customer procedures.
Supervision of the application of the measures and the activities determined by the AML and CTF Law are conducted by the following supervisory bodies:

  • the National Bank of the Republic of North Macedonia over the banks, savings houses, exchange offices, payment institutions, electronic money institutions and providers of money remittances (fast money transfer) and other financial institutions that provide payment services;
  • the Insurance Supervision Agency in the insurance companies, insurance brokerage companies, companies for insurance representation, insurance brokers, and insurance agents;
  • the Securities and Exchange Commission of the Republic of North Macedonia over the brokerage companies, banks that hold a license to work with securities, persons rendering investment advisory services, companies for management of open, closed, and private investment funds, and in open, closed, and private investment funds;
  • the Agency for Supervision of Fully Funded Pension Insurance over the companies that manage voluntary pension funds;
  • the Public Revenue Office regarding the organisers of games of chance, the legal entities and natural persons that provide the following services: intermediation in trade with immovables, tax advising, and legal entities that accept movable and immovable items as a pledge;
  • the Postal Agency over the Macedonian Post AD;
  • the Notary Commission within the Notary Chamber of the Republic of North Macedonia over the notaries; and
  • the Lawyers Commission within the Lawyers Chamber of the Republic of North Macedonia over the lawyers and law offices.
The Office supervises the application of the measures and activities determined the AML and CTF Law in the entities that are not covered above. The Public Revenue Office conducts supervision over legal entities and natural persons with regard to the application of the prohibition on cash payments in the amount of EUR 3,000 or more.


Customer Due Diligence

Conduct of a typical KYC identification process

Pursuant to the AML and CTF Law, entities are obliged to make the identification and the verification of the identity of the client, the proxy, or the beneficial owner, before they establish a business relationship or before they make an occasional transaction.

As an exception to the above, the entities may verify the identity of the client, the proxy, or the beneficial owner during the establishment of the business relationship, to not disturb the course of the business relationship and in the case of a low risk of money laundering and financing of terrorism.

Identification and verification of client's identity
If the client is a natural person, it should be identified and its identity should be verified by submitting an original and a valid document for identification, issued by a competent body, or a notary verified copy, or where possible, by using electronic identification means issued under the notified electronic identification scheme.

The document referred above, and if possible, the data for identification of persons that use electronic identification means, will determine the name, the surname, the date and place of birth, the place and address of the permanent or temporary residence, the personal identification number or the identification number, and the number of the personal identification document or the serial number of the electronic identification means, the body that has issued it, and the validity date, that is, the name of the issuer of the electronic identification means and the validity date of the electronic identification means.

If the client is a legal entity or a legal arrangement, it will be identified and its identity shall be verified by a registration document in original or a notary verified copy, issued by a competent body in the state of the legal entity's registration, or Articles of Incorporation of the legal arrangement. The registration or incorporation document shall be submitted in a paper and/or electronic form. The registration documents issued by a competent body of a foreign state should be translated in Macedonian language by an authorised court translator.

The document referred above will determine the name, the legal form, the head office, the tax number or other registration number of the legal entity or the legal arrangement, the founder(s), the trustee(s), the beneficiary, or a group of beneficiaries of the trust, the legal representative, the governing body, and the persons that are authorised for establishing a business relationship on behalf of the client.
The entities should mandatorily keep a copy of the documents in a paper form, as well as electronic records of the data for the purposes of identification of persons that used electronic identification means obtained by using electronic identification means issued under the notified electronic identification scheme and will apply the technical and organisational measures in accordance with the regulations on personal data protection.

The entities may also request other data, information, and documents from the client and/or reliable and independent sources for verification of the identity of the client.

Identification and verification of the identity of the proxy

The entities are obliged to determine whether the client acts on behalf and for the account of a third person. In the cases referred above, the entities are obliged to identify and verify the identity of the person who makes the transaction (the attorney-in-fact), the holder of the rights (the principal of the power of attorney) and the power of attorney document.

Identification and verification of the identity of the beneficial owner

The entities are obliged to identify the beneficial owner.

The entities are obliged to verify the identity of the beneficial owner on the basis of data and information from reliable and independent sources to the extent, which is adequate to the conducted risk assessment, so as to be assured who the beneficial owner is.
The entities will obtain the data on the beneficial owner from the original or verified documentation from a trade, court, or another public register, which must not be older than six (6) months. The entities will be obliged to check the data on the beneficial owner in the register of beneficial owners and must not rely exclusively on the data entered in the register.


If the entities cannot obtain all the data on the beneficial owner of the client from the trade, court or another public register or the register of beneficial owners, they should obtain the necessary data by checking the original or the verified documents and business records submitted by the legal representative of the client, or a person authorised by the legal representative.

If the client is not subject to entry into an appropriate register the entities cannot obtain the necessary data on the beneficial owner in the manner described above, the entities shall be obliged to obtain the data directly from the legal representative or a person authorised by the legal representative by a written statement which is notary verified under full moral and material liability.

If, during the determination of the beneficial owner, the entities have suspicions about the authenticity of the submitted data or the authenticity of the documents or the other business documentation, they will be obliged to require a written statement from the legal representative, or a person authorised by the legal representative which is verified by a notary under full moral and material liability before they establish a business relationship or before they make a transaction. In these cases, the entities are obliged to apply one (1) or several measures for enhanced due diligence

Possibility to meet customer due diligence requirements by relying on third parties who are obliged by law themselves to comply with AML regulations

In the cases where entities are obliged by law to implement the measures for the client's due diligence, they could entrust the performance of the measures and actions to third parties.

Entities that are required to conduct measures for the client's due diligence (Entities), can entrust the implementation of the following measures and activities to third parties:

  • identification of the client and verification of its identity by using documents, data, and information from reliable and independent sources, including, where possible, by using electronic identification means issued under the notified electronic identification scheme in accordance with the law;
  • identification of the principal of the power of attorney and verification of its identity by using documents, data, and information from reliable and independent sources, including, where possible, by using electronic identification means issued under the notified electronic identification scheme in accordance with the law;
  • identification of the beneficial owner and taking appropriate measures for verification of its identity by using documents, data, and information from reliable and independent sources in order for the entity to be assured who the beneficial owner is; and
  • obtaining information about the aim and purpose of the business relationship.
Additionally, Entities can, within the framework of its group, entrust the implementation of the measures and activities referred above to a third party which is part of the group provided that:

  • the group applies the measures and activities and monitors the obligations related to the keeping of data and has introduced and applies a program for prevention of money laundering and financing of terrorism containing elements; and
  • the implementation of the obligations at the level of the group is subject to supervision by the competent supervisory bodies determined in the AML/CTF Law or the competent supervisory bodies of a third country.
Providers of services to Entities or agents with which the Entities have concluded a contract for services, as well as entities established in high-risk countries, are not considered as third parties.

Please note that continuous monitoring of the business relationship and the transactions that are made within the established business relationship for the purpose of ensuring that such transactions are consistent with the risk profile and the business of the client and, if necessary, determination of the sources of funds, in the course of which the documents and data available to the entity must be updated, is not allowed to be entrusted to a third party.

Possibility to outsource customer due diligence by contract to other third parties who are not obliged by law to meet AML regulations and rely on these (e.g., WebID, IDnow, PostIdent)

No, it is not permitted. Please refer to our answer in question d. above.

Presence of a license or registration requirement for the third party in case of outsourcing customer due diligence

In case of outsourcing customer due diligence, Entities should establish that the third party is licensed for the activity it performs and is subject to control by a competent body and fulfils the client due diligence measures and keeping of data in accordance with the AML and CTF Law.



Further questions

Entities that could be relied on specifically by law as a third party to comply with AML regulations (regardless of outsourcing)
Yes credit institutions
Yes financial institutions
Yes auditors, external accountants, and tax advisors
Yes notaries and other independent legal professionals
Yes other trust or company service providers
Yes estate agents
Yes other persons trading high-value goods
Yes providers of gambling services
Yes Central Securities Depository
Yes Pawnshops


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