Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) Legislation in North Macedonia
Overview
The Republic of North Macedonia has implemented legislation to combat money laundering (ML) and terrorist financing (TF). This article provides a comprehensive overview of key aspects of the AML/CFT law, including definitions, reporting entities, customer due diligence, suspicious transactions, financial intelligence, whistle-blowing, offences and penalties, internal procedures, international sanctions, anti-bribery laws, and forthcoming issues.
Definitions
- Money Laundering (ML) and Terrorist Financing (TF): The AML/CFT law defines ML/TF as a process by which criminal proceeds are made to appear legitimate.
Reporting Entities
The following entities have been identified as having high risk of being used for ML/TF:
- Banks
- Financial institutions
- Insurance companies
- Securities dealers
- Casinos
- Exchange offices
- Money transfer operators
Customer Due Diligence (CDD)
Reporting entities must perform CDD on clients, including:
- Identifying the client
- Verifying their identity
- Understanding the purpose and nature of the business relationship or occasional transaction
- Conducting ongoing monitoring
- Reporting suspicious transactions
Suspicious Transactions
If a reporting entity suspects that a transaction is ML/TF related, it must report this to the Financial Intelligence Office (FIO) within one working day.
Financial Intelligence Office (FIO)
The FIO collects data from reporting entities on suspected ML/TF transactions and conducts investigations.
Whistle-blowing
There’s a law in place for whistle-blower protection, but it still needs substantial legal, institutional, and practical preparations to ensure effective implementation.
Offences and Penalties
The AML/CFT Law prescribes penalties for breaches related to ML/TF, including fines for individuals and reporting entities.
Internal Procedures and Training
Reporting entities must undertake procedures such as:
- Risk assessments
- Customer due diligence
- Submitting data to the FIO
- Appointing an authorized person
- Conducting internal control
- Ensuring professional training in preventing ML/TF
International Sanctions
The law implements international sanctions based on UN Security Council resolutions, EU legal acts, and other international organizations’ decisions.
Anti-Bribery and Corruption Laws
There’s a Law on the Prevention of Corruption and Conflict of Interests that regulates measures to prevent corruption in government, public authorizations, official duties, politics, and preventing conflict of interests.
Forthcoming Issues/Legislation
Despite alignment with EU acquis, more is needed to improve law enforcement effectiveness against money laundering and tracking record obligations.