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Azerbaijan’s Struggle Against Terrorist Financing and Money Laundering

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A recent report has revealed that the majority of suspicious transaction reports (STRs) in Azerbaijan relate to terrorist financing, yet few investigations or prosecutions have taken place. The country’s Prosecutor’s Office has failed to use the current criminal law effectively, despite having the necessary tools.

Limited Resources and Training

• Law enforcement authorities lack training and awareness on money laundering and terrorist financing issues.
• There is a perception that prosecuting money laundering cases would be difficult and add little value to convictions for predicate offenses.
• Authorities prioritize other crimes instead of pursuing money launderers.
• The country’s criminal law does not consider third-party laundering or the use of money laundering in organized crime.

Insufficient Definition of Terrorist Financing

• Azerbaijan’s definition of terrorist financing is narrow and insufficient as a predicate offense for money laundering.
• Prosecutors have only successfully prosecuted one case involving an individual collecting funds to finance future terrorist acts.

Implementation of UN Security Council Resolutions

• The country appears to have instituted a system for implementing United Nations Security Council Resolutions 1267 and 1373, but there is no guidance issued to non-banking sectors.
• Assets have not been frozen in conjunction with the resolutions.

Recommendations for Improvement

• Azerbaijan should prioritize improving its anti-money laundering (AML) and combating the financing of terrorism (CFT) regime by:
  • Amending its legislation.
  • Conducting awareness campaigns.
  • Establishing a financial intelligence unit.
• The country should also:
  • Prohibit bearer shares.
  • Provide targeted resources for law enforcement and prosecutors.
  • Establish coordination mechanisms between relevant authorities.

Additional Resources

• Worldwide AML Legislation (International Bar Association)
• Translation of Web Pages (Babel Fish)
• Country by Country AML Reports Library

Is Azerbaijan on any offshore jurisdiction blacklist?

No

Is Azerbaijan listed as a primary money laundering concern by the US Secretary of Treasury?

No

Is Azerbaijan identified as a supporter of international terrorism by the US Department of State?

No

Is Azerbaijan listed on the US Department of State International Narcotics Control Majors List?

No