National ML/TF risk assessment

Taking insufficient account of ML and TF risks makes the country’s response to threats and vulnerabilities more difficult. If the resources and activities of competent authorities and other stakeholders are not allocated in line with the risks found, the effects of such different segments of the system will be much less significant. If vulnerabilities are not identified and remedied on time, the danger that a threat will exploit a vulnerability becomes higher, so the country and individual sectors will be exposed to higher risk of being misused for ML or TF. This also jeopardises the country’s status in international organisations evaluating the AML/CFT measures the country takes.

NRA as a process and the document, which is the outcome of the analysis, are a major source of information providing guidance as to what segments of the system resources should be (re-)allocated. A NRA exercise identifies threats for the system and its vulnerabilities based on which conclusions are drawn with respect to the risks facing the various segments of the system at the national level and at the level of specific sectors. Regular review of risk is an international standard, and the requirement to conduct an NRA is also enshrined in the AML/CFT Law. The findings of the NRA are taken into account for the purpose of developing a national AML/CFT strategy, and all stakeholders are required to reallocate their resources in line with the findings of the NRA.

In order to mitigate the risks identified, an Action Plan is prepared as an indispensable part of the NRA exercise. The implementation of the NRA Action Plan is monitored by the national AML/CFT Coordination Body.

Serbia has conducted three ML/TF NRAs so far, the first being in 2013, and the two updates in 2018 and 2021.