Preventing and Combating Money Laundering: A Roadmap for Adapting the Regulatory Framework to the Context of the Republic of Moldova
Automatically translated summary. The full text is available in Romanian.
The Government of the Republic of Moldova has drafted a new law on preventing and combating money laundering and terrorist financing, aligning national legislation with best practices. Public consultations, in which Independent Think Tank “Expert-Grup” took part, agreed 12 changes and amendments, including higher thresholds for due diligence and reporting.
The consultations also removed individuals who rent out property from the list of reporting entities and substantially changed the chapter on sanctions, in particular how they are enforced. Despite these improvements, Expert-Grup argues the draft still has five major gaps. It does not transpose the definition of money laundering from EU Directive 2015/849, which the laws of six other states examined do include. It sets no due diligence measures for public institutions, although the “Landromat” case, involving the laundering of several billion dollars, exposed critical vulnerability in the judicial system. It also does not specify the obligations and responsibilities of SPCSB, and the selection of its leadership is not transparent enough.
The study sets out 13 principles for a balanced system and a roadmap with key steps for fixing the legal gaps and building rational secondary rules. The roadmap calls for clearly separating anti-money-laundering measures from counter-terrorist-financing measures, and prevention from direct combating.



