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Serbia: strides made in risk assessment and prosecution, further steps needed in supervision and effective use of financial intelligence, says Council of Europe anti-money laundering body

信息来源: 发布日期:2026-02-04

https://www.coe.int/en/web/moneyval/-/serbia-strides-made-in-risk-assessment-and-prosecution-further-steps-needed-in-supervision-and-effective-use-of-financial-intelligence-says-council-of-europe-anti-money-laundering-body-1

The Council of Europe’s anti-money laundering body, MONEYVAL, has released a new report assessing the effectiveness of Serbia’s measures against money laundering, countering terrorist financing and proliferation financing (AML/CFT/CPF) and their level of compliance with the Financial Action Task Force Recommendations, at the time of the on-site visit conducted in May 2025. The report acknowledges that regular national risk assessments have improved Serbian authorities’ understanding of AML/CFT risks, enabling more targeted mitigation measures. Co-ordinated policy efforts, including strategies, action plans, and effective monitoring, have contributed to progress. However, analysis of the influence of corruption on the AML/CFT regime remains fragmented and should be consolidated to better prioritize countermeasures.

Law enforcement and regulatory bodies actively engage in international co-operation, both formally and informally, including through joint investigations. Still, more proactive measures are needed to identify, seize and confiscate criminal assets across borders, especially regarding transnational organised crime. Authorities should also strengthen domestic co-ordination on asset recovery.

All financial supervisors can articulate sectoral money laundering and terrorism financing risks, with the National Bank of Serbia demonstrating advanced understanding, especially of the banking sector, MONEYVAL says. Supervisory planning and resource allocation are generally adequate, though staffing constraints have affected the Securities Commission’s work since 2022.

Some progress has been made in improving compliance among designated non-financial businesses and professions (DNFBPs) through outreach, supervision, remedial actions and sanctions. Most DNFBP supervisors have established internal procedures to support risk-based supervision, though implementation remains uneven. Further strengthening of institutional and sectoral risk understanding, supervisory engagement, and enforcement practices, particularly for lawyers and the Bar Association, is necessary, given the significance of the sector.

Serbia generally ensures the availability of basic and beneficial ownership data and facilitates access to it. The authorities’ controls are largely effective in ensuring data accuracy and currency. Further improvements are recommended to reduce overreliance on banks and the Tax Police, and to ensure that beneficial ownership data is accurate and up to date.

MONEYVAL recognises the central role of the Administration for Prevention of Money Laundering (APML) to the AML/CFT system, highlighting its broad access to data and the quality of its analytical and intelligence outputs. However, the report identifies structural and operational challenges which need addressing. Despite these gaps, APML disseminations support investigations and convictions, and information exchange among competent authorities functions effectively.

Money laundering convictions are on the rise, including cases involving both self- and third-party laundering. Prosecutions have resulted in indictments and convictions linked to several high-risk crimes, but MONEYVAL urges greater focus on laundering linked to high-level corruption and serious organised crime.

Several authorities are designated for financial investigations and asset confiscation, and different types of confiscation are applied. Although non-conviction-based confiscation is not legally available, the report notes a proactive approach to autonomous money laundering cases, and efforts to promote extended confiscation. Serbia also enforces controls on undeclared cross-border currency and negotiable instruments, applying sanctions as needed.

The terrorism financing risk in Serbia is identified as “medium”, mainly in the form of self-radicalised individuals and connections to armed conflicts in the Middle East and North Africa. The report notes a limited number of terrorism financing investigations, which only partly reflect Serbia’s identified risk profile. High evidentiary requirements and a lack of strategic coordination constrain overall effectiveness.

Serbia has strengthened its enforcement of targeted financial sanctions on terrorism and proliferation financing, promptly implementing UN Security Council Resolutions using an automated system. The APML acts swiftly, notifying reporting entities within 24 hours of new or updated listings. Written guidelines are recommended to streamline the handling of complex cases.

Following the assessment, Serbia received a roadmap of Key Recommended Actions to be completed within three years. Based on the Effectiveness and Technical Compliance Ratings received, Serbia has been placed under regular follow-up and is required to report back to MONEYVAL on progress made.