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Money Laundering and Combating Financing of Terrorism (ML/TF) in Kyrgyzstan: Progress Made and Remaining Shortcomings

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Summary

Recommendation 23 requires notaries and independent legal professionals involved in real estate transactions to report suspicious transactions and implement internal controls to conduct enhanced customer due diligence (CDD) on transactions with high-risk individuals.

Shortcomings Identified in the Mutual Evaluation Report (MER)

The original MER reported the following shortcomings:

• The requirement for notaries and independent legal professionals to report suspicious transactions was only partially implemented.
• These professionals were not obliged to implement internal controls and conduct enhanced CDD on transactions with persons from higher-risk countries.

Progress Made by Kyrgyzstan

However, since the initial assessment, Kyrgyzstan has made significant progress in addressing these shortcomings:

• The suspicious transaction reporting obligation established in Article 23 of Law No.87 extends to designated non-financial businesses and professions (DNFBPs), not just notaries and independent legal professionals.
• DNFBPs are required to implement internal control programs, including corporate (group-wide) internal control programs, that enable them to effectively comply with the AML/CFT legislation.

Remaining Shortcomings

Despite progress made, few shortcomings remain:

• Kyrgyzstan has not provided information on a special list of high-risk countries approved by the AML/CFT Commission.
• The measures set out in the Regulation on Procedure of Application of Measures (Sanctions) in Respect of High-Risk Countries are not applied consistently.

Ratings

Kyrgyzstan is re-rated as Low-Compliant (LC) with Recommendation 23, with a few shortcomings still remaining.