Peer Review Report – Second Round, Combined Review – Moldova

Determinations and Ratings

Largely Compliant: The overall rating for Moldova reflects the country’s efforts in addressing anti-money laundering (AML) and combating the financing of terrorism (CFT) measures.

The legal and regulatory framework is considered to be in need of improvement, requiring further development to ensure effective implementation of AML/CFT measures.

The following recommendations are made to strengthen Moldova’s AML/CFT regime:

Ensure ownership and identity information: Ensure that ownership and identity information for all relevant entities, including foreign companies and partnerships, is always available.
Improve beneficial ownership information: Improve the availability of beneficial ownership information for relevant legal entities, such as companies, partnerships, and co-operatives.
Clarify direct obligations for production cooperatives: Clarify direct obligations for production cooperatives to maintain identity and legal ownership information.
Specify retention periods for all types of cooperatives: Specify retention periods for identity and legal ownership information for all types of cooperatives.

Foreign companies and partnerships having a nexus to Moldova are not required to maintain ownership and identity information in all circumstances.
This gap exposes Moldova to potential risks associated with foreign entities operating within its jurisdiction without adequate oversight.

The CDD measures of AML-obliged persons may not hold beneficial ownership information for all legal entities.
There is a lack of specified frequency for some AML-obliged persons to update the beneficial ownership information of legal entities after the initial CDD measures.

Article 14 of the AML Law requires legal entities to maintain their beneficial ownership information, but relevant implementation mechanisms are still being developed.