Financial Crime World

Strengthening Moldova’s Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) Measures

Moldova has made progress in its efforts to combat Money Laundering (ML) and Terrorist Financing (TF), but there are still areas that require improvement. This article highlights key points and recommendations for strengthening Moldova’s AML/CFT measures.

Key Points: Current State of AML/CFT Measures

  • The Financial Institutions’ (FIs’) supervisors have a good understanding of ML risks in most sectors they supervise.
  • Supervisory actions have led to better governance by banking entities and some non-banking FIs, including improved internal risk assessments.
  • Notaries, lawyers, casinos, and dealers in precious metals and stones are subject to licensing/authorization requirements, but supervision of their compliance with AML/CFT obligations is limited.
  • The National Registration Agency (NRA) does not provide a comprehensive analysis of ML/FT risks related to legal entities (LEs).
  • LEAs rely on banks for access to beneficial ownership (BO) information and the bank account registry may improve data availability.

Recommendations: Enhancing AML/CFT Measures

1. Prioritize Business-Specific Risk Assessment

  • Regulatory bodies should assess their unique ML/FT threats and vulnerabilities, and apply Customer Due Diligence (CDD) and other risk-mitigating measures accordingly.
  • This approach will help identify high-risk areas and ensure that regulations are effective in preventing ML/FT.

2. Implement a New Suspicion-Based Transaction Reporting System

  • Moldova should implement this system as soon as possible, ensuring that Reporting Entities’ (REs’) internal processes for identifying and reporting ML/FT suspicions are effective and produce high-quality Suspicious Transaction Reports (STRs).
  • This system will improve the efficiency of identifying and reporting suspicious transactions.

3. Challenge Courts with More ML Cases

  • Moldova should rely on inferences from available evidence to challenge courts with more ML cases, addressing delays in international legal assistance requests.
  • By doing so, Moldova can increase the number of successful prosecutions for ML/FT.

4. Provide Sufficient Resources and Capacities for LEAs

  • LEAs should have access to financial intelligence resources, such as financial experts, forensic accountants, IT hardware, and software, to make effective use of financial intelligence.
  • This will enable LEAs to conduct thorough investigations and gather evidence.

5. Consistently Employ the Legislative Framework

  • Moldova should utilize its legislative framework to its full extent to raise the effectiveness of confiscation of proceeds from ML/FT activities.
  • By doing so, Moldova can strengthen its ability to combat ML/FT and disrupt criminal networks.

By implementing these recommendations, Moldova can enhance its AML/CFT measures, address identified shortcomings, and ensure a more effective and efficient fight against money laundering and terrorist financing.