The issue of liability is regulated differently in AML regulations. Article 91 of the AML clearly indicates that the performance by the obliged institution (bank) of the duties indicated above (Articles 86, 87 and 89), does not result in disciplinary, civil, criminal or other liability as defined by separate regulations.
The issue was similarly resolved in the UNRF, where the exclusion of all liability of the blocking entity, the supervised entity and persons acting on its behalf was explicitly prejudged.