Moldova’s Progress in Anti-Money Laundering and Combating Terrorism Financing

Assessment of AML/CFT Measures

The report assesses Moldova’s progress in implementing anti-money laundering (AML) and combating the financing of terrorism (CFT) measures. The Financial Intelligence Unit (FIU) has made significant improvements, with its supervisors having an adequate level of understanding of money laundering risks for most sectors they supervise.

Gaps in Supervision

However, gaps exist in supervising Designated Non-Financial Business and Professions (DNFBPs), such as:

• Notaries
• Lawyers
• Dealers in precious metals and stones

These sectors are not adequately supervised, which can lead to money laundering risks going undetected.

Transparency Concerns

The report highlights concerns regarding the transparency of legal persons and arrangements. Specifically:

• The Financial Supervisory Agency’s (FSA) ability to keep basic information on legal entities accurate and up-to-date is limited due to its lack of sanctioning power.
• There are insufficient measures in place to prevent the misuse of trusts and similar legal arrangements.

Reliance on Banks for Beneficial Ownership Information

The report also notes that the authorities rely heavily on banks to access beneficial ownership (BO) information, which can lead to challenges in verifying accuracy.

Recommendations for Improvement

To address these issues, the report recommends several priority actions:

• Ensure relevant entities prioritize ML/FT threat assessments and apply risk-mitigating measures
• Implement a new suspicion-based transaction reporting system
• Challenge courts with more ML cases
• Provide LEAs with sufficient resources and capacities
• Consistently employ the legislative framework to raise confiscation effectiveness