Money Laundering and Terrorism Financing Typologies - Info-Session for Public and Private Sector

On 1 July 2019 an info-session for public and private sector representatives was organized by the Serbia’s Chambre of Commerce to present and emphasise the significance of the Guidelines for establishing consolidated methodology for reporting on and tracking of ML/TF cases, as well as Money Laundering Typologies and Terrorism Financing Typologies. 

The Government issued the Guidelines for establishing consolidated methodology for reporting on and tracking of ML/TF cases on 3 May 2019. 

The Guidelines regulate tracking of ML/TF cases on one hand, and prescribe the information that all the institutions have to keep for the purpose of analysing efficiency and effectiveness of the system, on the other.  During the info session reasons for introducing these Guidelines which will enable various strategic analyses were explained, and the importance of resolving the problem of tracking ML/TF cases was emphasised.  The Guidelines were presented by the Head of Expert Team formed by the Chairman of AML/CFT Coordination body,  Mr. Miljko Radisavljević of Republic Prosecutors’ Office.

Chairman of the AML/CFT Coordination Body established the Team of Experts for developing ML and TF typologies on 11 March 2019.  The Team leader was Jelena Pantelić of APML, and members of the Team included representatives of Republic Prosecutors’ Office, Prosecutors’ Office for Organized Crime, Ministry of Interior, National Bank of Serbia, Securities Commission, Tax Police, Ministry of Justice, Office of the National Security Council, Security Information Agency. 

ML Typologies contain, on one hand, conducts typical for high-threat crimes (update of 2015 Typologies), but also, on the other hand,  typologies of ML cases where organized crime groups were identified, of stand-alone money laundering and professional money laundering.  Case studies both for predicate offences and for stand-alone and professional money laundering are the integral part of the document.  For each high-threat crime reasons for such a classification are explained, as well as the situation in the country, room for improvement and certain statistical data; this is followed by patterns of conduct, indicators typical of such crimes and red flags, which, when observed, require enhanced scrutiny by both preventive and repressive parts of the system.  The emphasis was also placed on higher risk crimes when it comes to cross-border threats and on sectors with greater exposure to this influence.  In addition to the typologies of higher threat crimes for money laundering, sectoral typologies have been issued as well, and they take into consideration assessed risks and situations recognized both in ML cases typical of a sector and in STRs.  Sectoral typologies are an appraisal of patterns of conduct in all obliged entities, according to the risk assesment.  Patterns of conduct in precious metals sector and in car trade have also been analysed and the patterns for trade-based money laundering have been illustrated. 

The Typologies contain trends and illustration of developments that obliged entities have to follow through in the period to come, international experience that has not been recognized in Serbia so far, but that has to be followed through in case it is observed, all of which aims at providing adequate responses to risks on a timely basis, as well as a set of recommendations for private and public sector; examples of good practice in inter-agency cooperation are emphasised.

 TF Typologies have been published in Serbia for the first time and they are based on risk assessment findings.  The Typologies contain both indicators and patterns of conduct typical of certain sectors, as well as challenges that may be encountered in the period to come.   In addition, the typologies provide recommendations with the aim to enhance both the identification of terrorism financing and coordination and cooperation of all stakeholders.

In terms of terrorist financing, particular attention was paid to the NPO sector and its inclusion into the AML/CFT system.

 ML Typologies and TF Typologies were presented by the authors and members of AML/CFT Coordination Body.