Moldova’s Anti-Money Laundering and Combating the Financing of Terrorism Efforts
Overall Assessment
Moldova has made significant progress in implementing anti-money laundering (AML) and combating the financing of terrorism (CFT) measures. However, there are still areas that require improvement, particularly in regards to risk assessment, suspicious transaction reporting, international cooperation, and confiscation.
Risk Assessment and Monitoring
- Good understanding of money laundering risks: Financial Institutions’ (FIs’) supervisors have a good understanding of money laundering (ML) risks in the majority of sectors they supervise.
- Better governance by FIs: Supervisory actions have led to better governance by banking entities and some non-banking FIs.
Non-Financial Businesses and Professions (DNFBPs)
- Gaps in supervisory framework: Certain gaps exist in the supervisory framework for DNFBPs, particularly regarding awareness-raising activities.
- Awareness-raising measures: Main measures adopted by supervisory authorities were related to awareness-raising activities regarding new AML/CFT requirements.
Transparency of Legal Persons and Arrangements
- Limited analysis of ML/FT risks: The National Risk Assessment (NRA) does not provide a comprehensive analysis of money laundering/financial terrorism (ML/FT) risks related to legal entities (LEs).
- Concerns regarding fictitious entities: Limited measures were applied by the Public Services Agency (PSA) to track down fictitious entities.
- Accuracy and update concerns: There are concerns regarding the PSA’s ability to keep information accurate and up-to-date without having sanctioning power.
International Cooperation
- Well-developed legal framework: The legal framework for providing international cooperation is well-developed and frequently used.
- Shortcomings in MLA: However, there are moderate shortcomings in Mutual Legal Assistance (MLA) on freezing and confiscation.
Priority Actions
- Assess business-specific ML/FT threats: Regulatory entities (REs) should prioritize the assessment of their business-specific money laundering/financial terrorism (ML/FT) threats and vulnerabilities.
- Implement suspicion-based transaction reporting system: Moldova should ensure that the new suspicion-based transaction reporting system is implemented as a matter of priority.
- Provide resources to LEAs: Law Enforcement Agencies (LEAs) should be provided with sufficient resources and capacities to make more effective use of financial intelligence.
- Employ legislative framework effectively: Moldova should consistently employ the legislative framework to the fullest extent, to raise the effectiveness of confiscation of proceeds.