National Money Laundering, Terrorist Financing аnd the Weapons оf Mass Destruction Proliferation Financing Risk Assessment

In a session held on 5 December 2024, the Serbian Government passed the conclusion adopting the National Money Laundering, Terrorist Financing and the Weapons of Mass Destruction Proliferation Financing Risk Assessment. The Assessment includes the Money Laundering Risk Assessment, the Terrorist Financing Risk Assessment, the Legal Persons and Arrangements Risk Assessment, the Money Laundering and Terrorist Financing Risk Assessment in the Digital Assets Sector, the Weapons of Mass Destruction Proliferation Financing Risk Assessment and the Risk Assessment of Terrorist Abuse in Non-Profit Organisations. The Assessments cover a three-year period, from 1 January 2021 to 31 December 2023, whereby Serbia reviewed and reassessed the risks in the system for the prevention of money laundering, terrorist financing and financing the proliferation of weapons of mass destruction.

The results of the National Risk Assessment are the product of joint work of the Government and private parts of system which lasted from June to December 2024. The working group for updating the National Risk Assessment, set up by the Serbian Government, was headed by the Public Prosecutor’s Office for Organised Crime, and members included representatives of the Administration for the Prevention of Money Laundering, Supreme Court, Supreme Prosecutor’s Office, Public Prosecutor’s Office for Organised Crime, Securities Commission, Security and Intelligence Agency, Ministry of the Interior, Ministry of Justice, Office of the National Security Council and Classified Information Protection and the National Bank of Serbia. More than 200 representatives from the public sector participated in the process, including representatives of the financial and non-financial sectors, in order to come to objective conclusions about the threats to and vulnerabilities of the system for the prevention of money laundering, terrorist financing and financing the proliferation of weapons of mass destruction.

The NBS participated in the assessment of AML vulnerability of the segment of the financial sector under its supervision, i.e. banking and insurance industries, financial leasing, voluntary pension funds, payment institutions, e-money institutions, exchange offices. The NBS also coordinated the preparation of the Money Laundering and Terrorist Financing Risk Assessment in the Digital Assets Sector. Within its scope of competence, the NBS also contributed to the development of the Terrorist Financing Risk Assessment, the Weapons of Mass Destruction Proliferation Financing Risk Assessment, the Risk Assessment of Terrorist Abuse in Non-Profit Organisations and the Legal Persons and Arrangements Risk Assessment.

In assessing sectoral vulnerabilities, we considered, among other things, the comprehensiveness of the legal network, effectiveness of supervisory procedures and practices, availability and application of governance and penal measures, system regulation in terms of licensing and other supervisory consents and approvals, employee integrity and level of knowledge related to money laundering and terrorist financing, efficiency of the compliance function, efficiency of monitoring and reporting suspicious transactions, and other factors of vulnerability.

Risk assessments seek to identify areas and actions in a country’s system which carry potentially higher or lower risk of money laundering and terrorist financing, in order for the Government to be able to adequately respond to identified risks by a series of measures and activities and make adequate decisions on resource allocation in accordance with the estimated risks, with a view to channelling more effort and resources into high-risk areas. Identification, assessment and understanding the risks of money laundering and terrorist financing represent essentially important segment of the application and development of the government’s AML/CFT system.  These risk assessments are also extremely important for the adequate application of AML/CFT regulations by the private sector.