Financial Crime World

Assessment of Moldova’s Anti-Money Laundering and Counter-Terrorist Financing Measures

Moldova has made progress in implementing anti-money laundering and counter-terrorist financing (AML/CFT) measures, but there are still gaps and weaknesses that need to be addressed.

Key Findings

  • The National Bank of Moldova (NBM) and the State Tax Service (STS) have an adequate understanding of money laundering (ML) risks for most sectors they supervise.
  • Supervisory actions have led to better governance by banking entities and some non-banking financial institutions.

Gaps and Weaknesses

  • Limited understanding of ML/FT risks related to legal entities (LEs), shell companies, trusts, and similar arrangements.
  • Inadequate supervision of the degree of compliance by designated non-financial businesses and professions (DNFBPs) with AML/CFT obligations.
  • Concerns regarding the accuracy and up-to-dateness of beneficial ownership (BO) information.

Recommendations

To address the gaps and weaknesses identified in the report, the following recommendations are made:

  1. Prioritize business-specific ML/FT threats and vulnerabilities: Regulatory entities should assess their business-specific ML/FT threats and vulnerabilities and apply CDD and other risk-mitigating measures that are appropriate in view of the risks identified.
  2. Implement new suspicion-based transaction reporting system: Moldova should ensure that the new suspicion-based transaction reporting system is implemented as a matter of priority, and REs’ internal processes aimed at identifying and reporting ML/FT suspicions are tested and supervised for effectiveness and quality of STRs produced.
  3. Challenge courts with more ML cases: Given the delays to requests for international legal assistance, Moldova should challenge the courts with more ML cases, relying on inferences that can properly be drawn from available evidence.
  4. Provide sufficient resources and capacities to LEAs: Law enforcement agencies (LEAs) should be provided with sufficient resources and capacities to make more effective use of financial intelligence (financial experts, forensic accountants, information technology (IT) hardware and IT software).
  5. Consistently employ legislative framework to the fullest extent: Moldova should consistently employ the legislative framework to the fullest extent, to raise the effectiveness of confiscation of proceeds.

These recommendations aim to improve Moldova’s AML/CFT regime by addressing the identified gaps and weaknesses.