Financial Crime World

Moldova’s Financial Crime Risk Assessment: Strengthening AML/CFT Measures against Money Laundering and Terrorist Financing

Executive Summary

This article provides an overview of the current state of anti-money laundering (AML) and countering the financing of terrorism (CFT) measures in the Republic of Moldova based on the October 2018 on-site visit conducted by international evaluators.

  • National Risk Assessment (NRA)

    • Conducted in 2017
    • Outlined threats, vulnerabilities, and risks related to money laundering and terrorism financing
    • Positive outcomes in addressing major risks but communication of results to reporting entities can be improved
    • Did not comprehensively address financing of terrorism risks

  • Service for Prevention and Fight of Money Laundering (SPCML)

    • Reasonable analysis procedure for developing financial intelligence
    • Used in law enforcement investigations related to money laundering and proceeds-generating offenses
    • High number of Suspicious Transactions Reports (STRs) necessitated managing internal analysis process
    • Data gathered from threshold reports useful for law enforcement agencies
    • Cooperation between domestic authorities is satisfactory

  • Money Laundering Cases

    • Several avenues for starting a ML case
    • Fluctuating number of investigated ML cases influenced by high-level cases
    • Convictions increasing, but only a limited number of investigations lead to prosecutions
    • Parallel financial investigations observed in proceeds-generating cases

  • AML/CFT Measures

    • Several strategic documents adopted and implemented
    • Country deprives criminals of proceeds from crime, with provisional measures available and applied
    • Asset management system recently reformed, but number and value of confiscated assets remain low

  • Terrorism Financing

    • Recognized as a low threat, with no evidence to suggest otherwise
    • Authorities demonstrated correct understanding of terrorism financing risks and have broad powers to obtain financial intelligence
    • Only two terrorism-related cases resulted in convictions, none involved terrorism financing aspect
    • Domestic cooperation between authorities established, alongside alternative measures, such as non-admission or deportation, to disrupt terrorism financing

Recommendations

  • Reporting Entities

    • Prioritize business-specific threats and vulnerabilities
    • Apply appropriate risk-mitigating measures

  • New Suspicion-Based Transaction Reporting System

    • Implement effectively

  • Law Enforcement Agencies

    • Provide sufficient resources and capacities
    • Make full use of legislative framework to increase confiscation of proceeds of crime or property of equivalent value

Continued efforts are required to strengthen Moldova’s AML/CFT system.