Financial Crime World

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Moldova’s Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) Framework: Key Findings

The report evaluates Moldova’s AML/CFT framework, highlighting areas of improvement and progress made.

Risk Assessment and Compliance


Financial Institutions’ supervisors have a good understanding of money laundering risks, but there is limited awareness among non-banking FIs. Supervisory actions have improved governance in banking entities, but non-bank FIs need more attention.

  • Financial Institutions’ supervisors have a good understanding of ML risks.
  • Non-banking FIs lack awareness of ML risks.
  • Supervisory actions have improved governance in banking entities.

The National Risk Assessment does not comprehensively analyze ML/FT risks related to legal entities (LEs). Authorities understand the misuse of shell companies, but there are concerns about the accuracy and update of LE information. Limited measures have been taken to track down fictitious entities.

  • The National Risk Assessment does not comprehensively analyze ML/FT risks.
  • Authorities understand the misuse of shell companies.
  • Concerns exist regarding the accuracy and update of LE information.

International Cooperation


Moldova’s legal framework for international cooperation is well-developed, with bilateral and multilateral agreements concluded. Authorities actively seek international assistance (MLA and extradition) for ML cases. However, there are some concerns about the quality and timeliness of responses to requests.

  • Moldova’s legal framework for international cooperation is well-developed.
  • Authorities actively seek international assistance.
  • Concerns exist regarding the quality and timeliness of responses.

Priority Actions


The report recommends:

  • Financial Institutions to prioritize assessing their business-specific ML/FT threats and vulnerabilities and apply risk-mitigating measures.
  • The new suspicion-based transaction reporting system should be implemented as a priority.
  • Moldova should challenge the courts with more ML cases, relying on inferences from available evidence.
  • Law enforcement agencies (LEAs) should be provided with sufficient resources and capacities to make effective use of financial intelligence.
  • Moldova should consistently employ its legislative framework to raise the effectiveness of confiscation of proceeds.

Conclusion

While Moldova has made progress in strengthening its AML/CFT framework, there are still areas for improvement, particularly related to non-banking FIs, LEs, and international cooperation.