Action Plan for the Implementation of Recommendations from Money Laundering Risk Assessment and Terrorism Financing Risk Assessment
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Government adopts the Guidelines for Establishing Consolidated Methodology for Reporting on and Tracking of ML/TF Cases
The Government has isued a conclusion on the adoption of the Guidelines for establishing consolidated methodology for reporting on and tracking of ML/TF cases.
The Chair of the AML/CFT Coordination Body established on 28 October 2018 an expert team for developing the Guidelines for preparing statistical reports. A representative of the Republic Prosecutor’s Office was appointed Head of the expert team, and representatives of Supreme Court of Cassation, Republic Prosecutor’s Office, Prosecutor’s Office for Organized Crime, APML, Ministry of Interior, Customs Administration, Tax Police, Security Information Agency, Ministry of Justice, Business Registers Agency and Republic Statistics Office were appointed members of the Expert team.
Several prioritized activities from the Action Plan for the Implementation of NRA refer to the analysis of the state-of-play and data-keeping by relevant AML/CFT stakeholders, as well as to the need to establish a consolidated methodology for reporting on ML/TF cases. As a measure to address the deficiency, a need to establish a consolidated system of statistical tracking of ML/TF cases has been identified, starting from initial information, a SAR, and ending with a sentence.
To improve consistency and avoid possible discrepancies, a conclusion was made during the NRA process that there should be consolidated guidelines which will serve as an instruction for state authorities to keep ML/TF track record, as well as the data necessary for the analysis of effeicency and effectiveness of the system.
These Guidelines align and direct tracking of and reporting on ML/TF cases, as well as recording and exchanging of information, with the aim of a consolidated action and a more reliable assessment of the efficiency of AML/CFT system and the implementation of NRA.
For the purpose of a more efficient tracking of ML/TF cases, the Guidelines establish statistical data records for ML/TF cases; a range of state authorities and institutions will be in charge of record-keeping, APML included. According to these Guidelines, state authorities and institutions will enter the data they act upon into relevant forms, which will subsequently be referred to the Republic Prosecutor’s Office and relevant prosecutor’s office or Prosecutor’s Office for Organized Crime and Standing Inter-Agency Working Group. Until the planned web application is introduced, state authorities and institutions will provide the forms electronically. The web application will be developed within the Project on enhancing the quality and efficiency of suspicious transactions reporting (STR) and Administration for the Prevention of Money Laundering (APML) core functions, which is financed by the EU. The benficiary of the Project is the Ministry of Finance - Administration for the Prevention of Money Laundering, and the Project is implemented by a consortium led by KPMG.
Additionally, for the purpose of conducting NRA on ML and TF, the Guidelines provide for a requirement placed upon state authorities, organizations and professional associations to record the data relevant for NRA. The data is recorded for a period of one year and is provided to the APML and AML/CFT Coordination Body, by 1 March of the current yeaer for the preceeding year at the latest.
The Guidelines were adopted at the Government session which was held on 3 May 2019.