Financial Crime World

Moldova’s Progress in Anti-Money Laundering and Counter-Terrorist Financing

Introduction

The Republic of Moldova has made significant progress in implementing Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) measures. However, there are still areas that require improvement.

Challenges and Areas for Improvement

Supervision of Non-Bank Financial Institutions (NBFIs)

  • Effective supervision of NBFIs is essential to prevent money laundering and terrorist financing.
  • Current challenges:
    • Limited resources and capacities for regulatory bodies
    • Insufficient understanding among authorities and banks regarding trusts and similar legal arrangements

Law Enforcement Agencies (LEAs) Capabilities

  • LEAs require sufficient resources and capacities to effectively use financial intelligence.
  • Current challenges:
    • Inadequate resources and capacities for LEAs
    • Limited understanding among authorities and banks regarding trusts and similar legal arrangements

Recommendations

Enhance Risk Assessment

  • Ensure that Reporting Entities (REs) prioritize the assessment of their business-specific ML/FT threats and vulnerabilities.
  • Apply Customer Due Diligence (CDD) and other risk-mitigating measures.

Implement a New Suspicion-Based Transaction Reporting System

  • Prioritize the implementation of a new system for reporting suspicious transactions.
  • Test and supervise REs’ internal processes for identifying and reporting ML/FT suspicions.

Improve International Cooperation

  • Challenge courts with more ML cases to reduce delays in requests for international legal assistance.
  • Rely on inferences that can properly be drawn from available evidence.

Enhance Resources and Capacities for LEAs

  • Provide LEAs with sufficient resources and capacities to make effective use of financial intelligence.
  • Include financial experts, forensic accountants, IT hardware and software.

Consistently Employ the Legislative Framework

  • Raise the effectiveness of confiscation of proceeds by consistently employing the legislative framework.

Priority Actions

  1. Enhance risk assessment: Ensure that REs prioritize the assessment of their business-specific ML/FT threats and vulnerabilities.
  2. Implement a new suspicion-based transaction reporting system: Prioritize the implementation of a new system for reporting suspicious transactions.
  3. Improve international cooperation: Challenge courts with more ML cases to reduce delays in requests for international legal assistance.
  4. Enhance resources and capacities for LEAs: Provide LEAs with sufficient resources and capacities to make effective use of financial intelligence.
  5. Consistently employ the legislative framework: Raise the effectiveness of confiscation of proceeds by consistently employing the legislative framework.