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Financial Sanctions and Freezing of Terrorist Funds: Progress in “the former Yugoslav Republic of Macedonia”

An international organization has conducted a mutual evaluation of “the former Yugoslav Republic of Macedonia”, highlighting significant progress in addressing financial sanctions and freezing terrorist funds. Below are the main points related to this effort:

Deficiency No. 1: Lack of Guidance for Implementing Financial Measures

• The new Law provides a more adequate framework for targeted financial sanctions.
• However, the Law does not contain enough indications on how to implement financial measures once a designation is made.
• Draft guidelines have been provided and are assessed positively by the Secretariat, but they are still in draft form.

Deficiency No. 2: Lack of Legislation for Freezing under Procedures Initiated by Third Countries and Funds or Assets Controlled by Designated Persons

• This deficiency has been fully addressed through the adoption of the new 2017 IRM Law.

Deficiency No. 3: No Designation Authority in Place for UNSCR 1373

• This deficiency has been fully addressed through the adoption of the new IRM Law, which appoints competent domestic authorities to make proposals for designations.

Deficiency No. 4: Lack of Protection for Bona Fide Third Parties

• This deficiency has been fully addressed through the adoption of the new IRM Law, which provides provisions protecting the interests of bona fide third parties affected by the freezing mechanism.

Deficiency No. 5: Lack of Procedures for Considering De-Listing Requests and Unfreezing Funds or Other Assets

• This deficiency has been partially addressed through the adoption of the new IRM Law, which provides a framework for considering de-listing requests and unfreezing assets.