Financial Crime World

Anti-Money Laundering and Counter-Terrorist Financing Measures in the Republic of Moldova

Executive Summary

The report assesses the progress made by the Republic of Moldova in implementing anti-money laundering (AML) and counter-terrorist financing (CTF) measures. While there have been positive developments, areas for improvement remain.

Key Points

  • Supervisory Framework: Financial Institutions’ supervisors demonstrate a good understanding of ML risks, leading to improved governance among banking entities and some non-banking financial institutions.
  • Non-Bank Financial Businesses and Professions (DNFBPs): The supervisory framework for DNFBPs is limited, with only recent measures for awareness-raising activities regarding AML/CFT obligations.
  • Legal Persons and Arrangements: The NRA does not provide a comprehensive analysis of ML/FT risks related to legal entities. However, shell companies are well-understood by the authorities, and measures have been taken to prevent misuse, particularly in uncovering VAT fraud.
  • International Cooperation: The 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.

Priority Actions

  • Risk-Based Approach: Regulatory bodies should prioritize business-specific ML/FT threats and vulnerabilities and apply Customer Due Diligence measures accordingly.
  • Suspicion-Based Transaction Reporting System: The new system should be implemented as a priority, with internal processes aimed at identifying and reporting ML/FT suspicions tested and supervised for effectiveness.
  • ML Case Prosecution: Courts should challenge prosecution of more ML cases relying on inferences from available evidence.
  • Resource Allocation: Law Enforcement Agencies should be provided with sufficient resources to make effective use of financial intelligence.
  • Legislative Framework: The legislative framework should be consistently employed to raise the effectiveness of confiscation of proceeds.