Financial Crime World

Anti-Money Laundering and Counter-Terrorism Financing (AML/CFT) Measures in the Republic of Moldova

Financial Institutions

Financial institutions in the Republic of Moldova play a crucial role in preventing money laundering (ML) and financing of terrorism (FT). However, there are areas that require improvement.

  • Supervision Gaps: Supervisors have a good understanding of ML risks, but there are gaps in supervising non-banking financial institutions.
  • Improved Governance: Supervisory actions have led to better governance by banking entities and some non-banking FIs.

Designated Non-Financial Business and Professions (DNFBPs)

The following DNFBPs are subject to licensing/authorization requirements:

  • Notaries
  • Lawyers
  • Casinos
  • Dealers in precious metals and stones

However, there are gaps in the supervisory framework, with a focus on awareness-raising activities rather than effective supervision.

The National Risk Assessment (NRA) does not provide a comprehensive analysis of ML/FT risks related to legal entities (LEs).

  • Prevention Measures: Authorities have taken steps to prevent misuse of LEs, but limited measures were applied by the Public Services Agency (PSA) to track down fictitious entities.
  • Information Accuracy: There are concerns about the PSA’s ability to keep information on LEs accurate and up-to-date without sanctioning power.

International Cooperation

The Republic of Moldova has a well-developed legal framework for international cooperation, with bilateral and multilateral agreements concluded.

  • Active Assistance: Authorities actively seek international assistance (MLA and extradition) for ML cases, but there are some issues with timeliness and quality of responses.
  • Effective Cooperation: Moldova has demonstrated its ability to cooperate with counterparts upon their own initiative and upon requests.

Priority Actions

To improve the AML/CFT regime in the Republic of Moldova, the following priority actions are recommended:

  1. Business-Specific Risk Assessment: Ensure that reporting entities prioritize assessing business-specific ML/FT threats and vulnerabilities and apply CDD measures accordingly.
  2. Suspicion-Based Transaction Reporting System: Implement a new suspicion-based transaction reporting system as a matter of priority.
  3. Court Cases: Challenge courts with more ML cases, relying on inferences from available evidence.
  4. Resources for LEAs: Provide LEAs with sufficient resources and capacities to make effective use of financial intelligence.
  5. Confiscation of Proceeds: Consistently employ the legislative framework to raise the effectiveness of confiscation of proceeds.

Overall, the report highlights areas for improvement in Moldova’s AML/CFT regime, including enhancing supervision of DNFBPs and ensuring that LEAs have the necessary resources and capacities to effectively combat ML.