Article 14.
Money Laundering

Article provisions:
1. Each State Party shall:
(a) Institute a comprehensive domestic regulatory and supervisory regime for banks and non-bank financial institutions, including natural or legal persons that provide formal or informal services for the transmission of money or value and, where appropriate, other bodies particularly susceptible to moneylaundering, within its competence, in order to deter and detect all forms of money-laundering, which regime shall emphasize requirements for customer and, where appropriate, beneficial owner identification, record-keeping and the reporting of suspicious transactions;
(b) Without prejudice to article 46 of this Convention, ensure that administrative, regulatory, law enforcement and other authorities dedicated to combating money-laundering (including, where appropriate under domestic law, judicial authorities) have the ability to cooperate and exchange information at the national and international levels within the conditions prescribed by its domestic law and, to that end, shall consider the establishment of a financial intelligence unit to serve as a national centre for the collection, analysis and dissemination of information regarding potential money-laundering.
2. States Parties shall consider implementing feasible measures to detect and monitor the movement of cash and appropriate negotiable instruments across their borders, subject to safeguards to ensure proper use of information and without impeding in any way the movement of legitimate capital. Such measures may include a requirement that individuals and businesses report the cross-border transfer of substantial quantities of cash and appropriate negotiable instruments.
3. States Parties shall consider implementing appropriate and feasible measures to require financial institutions, including money remitters:
(a) To include on forms for the electronic transfer of funds and related messages accurate and meaningful information on the originator;
(b) To maintain such information throughout the payment chain; and
(c) To apply enhanced scrutiny to transfers of funds that do not contain complete information on the originator.
4. In establishing a domestic regulatory and supervisory regime under the terms of this article, and without prejudice to any other article of this Convention, States Parties are called upon to use as a guideline the relevant initiatives of regional, interregional and multilateral organizations against money-laundering.
5. States Parties shall endeavour to develop and promote global, regional, subregional and bilateral cooperation among judicial, law enforcement and financial regulatory authorities in order to combat money-laundering.

State evaluation
Public evaluation
National legislation of Ukraine is consistent with Article 14 on the prevention of money laundering of the UN Convention against corruption. The financial intelligence unit (SFMS) functions. Necessary tools have been created for prompt response to detected violations in terms of money laundering. The profile legislation was updated, which was positively assessed by MONEYVAL.
The activities of the financial intelligence unit in Ukraine (SFMS) and its cooperation with internal and external stakeholders can be highly appreciated. At the same time, the inadequate ability of law enforcement agencies to investigate possible violations identified by SFMS is not conducive to systematic investigation and prosecution of the identified violations.

In short:

State of implementation

Legal framework

1.1. Financial Intelligence Unit in Ukraine
In 2010, Ukraine ratified the Council of Europe Convention on Laundering, Search, Seizure, and Confiscation of the Proceeds from Crime and on the Financing of Terrorism. Under paragraph 13 of Article 46 of this Convention, the body authorized by Ukraine to perform the functions of a financial intelligence unit (hereinafter—FIU) is the State Financial Monitoring Service of Ukraine (hereinafter—SFMS). Its activities are directed and coordinated by the Cabinet of Ministers of Ukraine through the Minister of Finance.
The tasks, functions, and powers of the SFMS are established by the Law of Ukraine "On Prevention and Counteraction to Legalization (Laundering) of Proceeds from Crime, Financing of Terrorism and Financing of the Proliferation of Weapons of Mass Destruction" (hereinafter Law on Money Laundering) and the Regulation on this agency. Regarding internal and external cooperation, one of the tasks of the SFMS is to establish cooperation with government agencies, competent authorities of foreign countries, and international organizations in the field of prevention of and response to money laundering.

1.2. Financial monitoring system
A financial monitoring system has been established and is operating in Ukraine. The financial monitoring system consists of primary and national levels. The subjects of state financial monitoring are the National Bank of Ukraine, the Ministry of Finance of Ukraine, the Ministry of Justice of Ukraine, the National Commission on Securities and Stock Market, the Ministry of Digital Transformation of Ukraine, and the SFMS itself. Each of them supervises individual subjects of primary financial monitoring. However, some of these bodies have certain legislative features.
The Ministry of Justice of Ukraine noted that since the entry into force of the new version of the Law on Money Laundering (April 28, 2020), scheduled and unscheduled inspections of primary financial monitoring subjects were not conducted due to the fact that to date, the Cabinet of Ministers has not adopted a legal act regulating the procedure for such inspections. Accordingly, the Ministry did not take any measures to influence the SPFM over this period.
As for the Ministry of Digital Transformation of Ukraine, due to the lack of legal regulation of the circulation of virtual assets in Ukraine, the Ministry of Digital Transformation cannot currently fulfill its responsibilities as the subject of state financial monitoring. Such regulation is only being introduced by the Verkhovna Rada.
In accordance with the Law on Money Laundering, the SFMS generates summary materials—information on financial transactions which were the object of financial monitoring and which the analysis found suspicious. The summary materials are a source of circumstances that may indicate the commission of a criminal offense and give grounds to the investigator or the prosecutor to initiate a pre-trial investigation.
The subjects of primary financial monitoring (hereinafter—SPFM) are banks, insurers, credit unions, payment organizations, commodities, and other exchanges, etc. The procedure for carrying out financial monitoring measures by these entities is regulated by a separate resolution of the NBU. SPFMs are required to apply a risk-based approach in their activities, taking into account the relevant risk criteria. If there is information about suspicious transactions, SPFM must immediately notify the SFMS.
The Law of Ukraine “On Currency and Currency Transactions” establishes the legal basis for foreign exchange transactions, currency regulation, and currency supervision. If violations of a currency transaction subject are identified, the bank or another financial institution prevents such a foreign exchange transaction. An individual does not need to make a written declaration of cash currency and bank metals to the customs authority, provided that their value does not exceed 10,000 euros. If the amount is equal to or exceeds 10,000 euros, a written declaration to the customs authority is made in full.
The Customs Code of Ukraine establishes administrative liability for:

Non-declaration of goods, commercial vehicles moving across the customs border of Ukraine.
A fine of 100 percent of the value of these goods, vehicles, and their confiscation
Movement across the customs border of Ukraine of goods that are prohibited to move across the customs border.
A fine of about 50 euros and confiscation of goods
Implementation in practice






2.1. State financial monitoring and its cooperation
The SFMS went into operation in 2002 as part of the Ministry of Finance of Ukraine as the State Department of Financial Monitoring. Since 2005, the SFMS has become a separate executive body. The independence of the SFMS is ensured due to the system of prevention and counteraction to money laundering built since 2005, the availability of a risk-oriented approach and software that enables quick tracking and blocking of all suspicious transactions, and creating summary materials to send them to law enforcement agencies. According to experts, there is no political interference in the agency’s activities.
1) Cooperation at the domestic level
The SFMS actively works with various public agencies in Ukraine and at the international level. In Ukraine, the SFMS has signed acts on information exchange with six state regulators, eight state law enforcement agencies (such as the MIA, the NABU, the ARMA, the SIB, the Prosecutor General’s Office, etc.), thirteen other state agencies (such as the SPFU, the AMCU) and one institution (the National Depository of Ukraine). It has also signed twenty-three Memoranda with public agencies, institutions, and organizations, and eleven joint orders of the SFMS with public regulators and other public agencies.
Employees of the SFMS indicate that access to databases of state bodies is open, permanent, and provided as required. Information on requests from the SFMS is received on time and in full. At the same time, information from public bodies at their own initiative (if they identify financial violations) does not come in full. One such reason is their frequent reorganization and, as a consequence, the need to renegotiate information exchange agreements.
At the domestic level, the SFMS constantly cooperates with SPFM. Thus, for the last 5 years, SPFMs have provided the following number of notifications on financial transactions subject to financial monitoring:
In 2016, banks sent 6,260,727 notifications on financial transactions subject to financial monitoring, 59,049 notifications were sent by non-banking financial institutions.
In 2017, banks sent 7,940,799 notifications on financial transactions subject to financial monitoring, 72,701 notifications were sent by non-banking financial institutions.
In 2018, banks sent 9,871,608 notifications on financial transactions subject to financial monitoring, 98,184 notifications were sent by non-banking financial institutions.
In 2019, banks sent 11,327,040 notifications on financial transactions subject to financial monitoring, 110,334 notifications were sent by non-banking financial institutions.
In 2020, banks sent 4,675,432 notifications on financial transactions subject to financial monitoring, 50,105 notifications were sent by non-banking financial institutions.
The decrease in the number of notifications in 2020 was due to the adoption in 2019 of a new version of the Law of Ukraine on Money Laundering, which raised the threshold for reporting financial transactions and introduced case reporting on suspicious transactions. This change was welcomed by experts, who noted that, in summary, the new version of the Law meets the requirements of European directives, the requirements of MONEYVAL, and allows increasing the level of competition in this area.

2) Cooperation at the international level
At the international level, the SFMS actively cooperates with:
- The Council of Europe Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism (MONEYVAL). In 2017, Ukraine passed the 5th round of mutual evaluation of the national financial monitoring system by the MONEYVAL Committee, which resulted in the MONEYVAL Committee publishing the Report on Mutual Evaluation of Ukraine in January 2018;
- Conference of the Parties to the Council of Europe Convention on Laundering, Search, Seizure and Confiscation of the Proceeds from Crime and on the Financing of Terrorism (CEST No. 198);
- Financial Action Task Force (FATF).
- Egmont Group of Financial Intelligence Units. Since 2004, the SFMS has been a member of the Egmont Group. In particular, in its activities, the SFMS uses the information exchange system of the Egmont Group of Financial Intelligence Units.
- United Nations Office on Drugs and Crime (UNODC),
and other international partners.
During 2003-2020, 82 Memoranda of Understanding were signed with FIUs of foreign countries.
According to the information provided by the SFMS, in 2019, 356 requests were sent to 61 FIUs of foreign countries and 335 responses to requests from foreign countries were received. In addition, the SFMS received 287 requests from 50 FIUs of foreign countries and provided 287 responses. The most active exchange of information is with the FIUs of Latvia, Cyprus, Switzerland, Germany, and the United States.
In 2020, the SFMS sent 328 requests to 59 FIUs of foreign countries (in addition, 197 additional requests were sent to 47 FIUs of foreign countries) and 410 responses were provided to 55 FIUs of foreign countries (in addition, 216 additional responses were sent to 39 FIUs of foreign countries), and 4 spontaneous messages were sent to 4 FIUs of foreign countries. The most active exchange of information took place with the FIUs of the Czech Republic, Poland, Latvia, Switzerland, Cyprus, Slovakia, and Lithuania.
In the first six months of 2021, the SFMS sent 321 requests to 64 FIUs of foreign countries and received 186 requests from 45 foreign FIUs. The most active exchange of information took place with FIUs from Latvia, Poland, Switzerland, Hungary, Cyprus, Germany, Montenegro, and Turkey.
From these data, we can make a conclusion about the high and constant level of cooperation of the SFMS at the international level. It should be noted that foreign countries provide information in accordance with the requirements of their own legislation. Therefore, in some cases, not all the information requested by the SFMS can be provided. Similarly, the Ukrainian FIU forms a response to the request taking into account the requirements of domestic law, as well as the likely consequences for law enforcement agencies of Ukraine that investigate criminal cases. If the information may prejudice the investigation of the case, the response to the request shall be provided only in the part that will not prejudice the investigation.
2.2. Features of the new version of the Law on Money Laundering
There appeared to be some shortcomings in the realization of the latest version of the Law on Prevention and Counteraction. Banking institutions have an obligation to ensure the automatic exchange of information between them and the SFMS. While large banks have the financial resources and understanding of how to implement this, small banks do not.
To eliminate this problem, e-profiles of SPFMs are envisioned. E-profiles will provide an opportunity for simplified submission of SPFM notifications to the SFMS. The relevant Decree of the Ministry of Finance will come into force at the end of November 2021. In general, this step speeds up the speed of providing information and saves SPFM financial resources, which is absolutely a positive aspect. At the same time, one of the challenges at the current stage is to ensure the security of channels for the transmission of this information by the government.
Also, the new version of the Law on Money Laundering formalizes a risk-oriented approach in the activities of banking institutions. In particular, they are obliged to determine the risk criteria themselves, taking into account information from government regulators. At the same time, according to the experts we interviewed, in practice, this leads to a different approach to risk formation. There may be a situation in which the same customer will be assigned to different risk categories in different banks, which will not contribute to a uniform practice of their application. Still, the employees of the SFMS see a positive aspect in this as well. In their opinion, such a varied approach allows developing a variety of criteria, which will accelerate and improve the development of their application.
To address the issue of a risk-based approach, experts suggest either clearly establishing criteria at the NBU level and providing them to banks to ensure a unified approach, or establishing separate key criteria for assigning individuals to different risk groups, and additional criteria which banks would be able to establish themselves. For its part, in 2020, the SFMS presented a Guide to a Risk-Oriented Approach for Specially Defined SPFM for a better understanding of risks and a risk-oriented approach.
2.3. Activities of other subjects of state financial monitoring
As mentioned above, the subjects of state financial monitoring are the NBU, the Ministry of Finance, the NSSMC, the Ministry of Justice, the Ministry of Digital Transformation, and the SFMS itself. Each of them conducts activity monitoring for SPFMs which are under their jurisdiction. In general, it should be noted that the subjects of state financial monitoring have different approaches to conducting inspections of SPFMs. Some of them conduct rather few inspections (no more than twenty a year), and some cannot conduct them due to the lack of designated legislation. Others conduct numerous inspections and apply sanctions. It should also be noted that the mechanism for notifying the SFMS is underdeveloped—entities do not report frequently. While many violations are found, the size of penalties is not burdensome for SPFMs.
The National Bank of Ukraine provided the following information for the last three years:
In 2019 – 91 inspections (including planned inspections, non-planned ones, and off-site oversight).
In 2020 – 97 inspections (including planned inspections, non-planned ones, and off-site oversight).
In 2021 (as of the 30th of September, 2021) – 130 inspections (including planned inspections, non-planned ones, and off-site oversight).
In 2019, the NBU applied 41 oversight measures, particularly: 27 fines in the total sum of more than EUR 1,5 million and 14 warnings made in writing. In 2020, there were 30 oversight measures taken, particularly: 21 fines in the total sum of more than EUR 500000 and 9 warnings made in writing. In 2021 (as of the 30th of September, 2021) there were 43 oversight measures, particularly: 1 written agreement, 1 decision to annul the license, 6 fines in the total sum of more than EUR 300000, and 35 warnings made in writing.
The Ministry of Justice of Ukraine (and its territorial bodies) provided information for 2019 and the first quarter of 2020:
2019 — 1902 SPFM inspections (1863 scheduled, 39 unscheduled).
The first quarter of 2020 — 317 (313 planned inspections, 4 unscheduled ones).
During 2019, the commissions of the Ministry of Justice / Departments of Justice on the application of sanctions for violations of the law in the field of financial monitoring adopted 413 decisions on sanctions to SPFMs in the form of a fine totaling approximately 10,000 euros; during the first quarter of 2020 - 27 decisions on the application of sanctions in the form of a fine totaling approximately 500 euros.
During 2019, the SPFM (under the Ministry of Justice) submitted 15 notifications on financial transactions to the SFMS, of which 11 notifications were registered with the SFMS. During 2020—26 notifications of financial transactions, of which 15 notifications were registered; during 9 months of 2021—12 notifications on financial transactions, of which 6 notifications were registered with the SFMS.
For the last three years, the NSSMC has provided the following information:
2019 — 34 inspections (27 scheduled and 7 unscheduled).
2020 — 13 inspections (8 scheduled and 5 unscheduled).
I-III quarters of 2021 — 17 inspections (15 scheduled and 2 unscheduled).
Penalties applied:
2019 — 24 (total amount approximately 2500 euros).
2020 — 7 (approximately 1200 euros).
I-III quarters of 2021 — 2 (approximately 2200 euros).
A number of messages were sent to SFMS: 2019 — 1, 2020 — 1, 2021 — 2.
The Ministry of Finance provided the following data:
In 2019, 22 scheduled inspections of SPFMs were conducted, with violations of the requirements in the field of financial monitoring found in 22 entities.
In 2019, 2 meetings of the Commission of the Ministry of Finance on the Application of Penalties were held, as a result of which 19 cases were considered on the basis of inspections conducted in the I-III quarters of 2019, and 19 decisions were made to impose a fine totaling more than 20,000 euros.
In May 2020, a meeting of the Commission of the Ministry of Finance on the Application of Penalties to SPFMs was held, resulting in 3 cases considered on the basis of inspections conducted in the I-III quarters of 2019, and 3 decisions were made to impose fines totaling more than 3,300 euros. In 2020 and over 9 months of 2021, the Ministry of Finance has not conducted inspections of SPFMs, and no notifications were sent to the SFMS.
2.4. Assessment of the national financial monitoring system
In 2017, Ukraine passed the 5th round of mutual evaluation of the national financial monitoring system by the MONEYVAL Committee, which resulted in the MONEYVAL Committee publishing the Report on Mutual Evaluation of Ukraine in January 2018. The appendix to the Report provides a detailed analysis of the level of compliance with the FATF 40 Recommendations:
Compliant — 12 recommendations;
Largely compliant — 20 recommendations;
Partially compliant — 7 recommendations;
Not applicable — 1 recommendation.
In the next two years, Ukraine’s progress in complying with these recommendations must be assessed.
In 2 years, Ukraine has raised its score on two recommendations — No. 5 “Terrorist financing offense” and No. 35 “Sanctions,” although the score dropped on two other recommendations, No. 15 “New technologies” and No. 21 “Tipping-off and confidentiality.” Thus, progress in improving the FATF recommendations is slow. However, the initial assessment is quite optimistic, which gives hope that the score on other FATF recommendations will be raised in the future.
In 2019, the 1st Enhanced Follow-up Report & Technical Compliance Re-Rating was received (conducted by the Isle of Man and Israel). In conclusion, limited measures have been taken to implement the new elements under Recommendations 2, 7, 18, and 21. As a result, Recommendation 21, initially rated as C (compliant), is re-rated as LC (largely compliant).
In 2020, the 2nd Enhanced Follow-up Report & Technical Compliance Re-Rating was published (conducted by the Isle of Man and Cyprus). Overall, Ukraine has made progress in addressing the gaps in technical compliance identified in the MER in the 5th round of mutual evaluations and has been reassessed on the implementation of the Recommendations. Recommendations No. 5 and No. 35, initially assessed as PC (partially compliant), were reassessed as LC (largely compliant). Recommendation No. 15, initially assessed as LC (largely compliant), was reassessed as PC (partially compliant). Further evaluations will be subject to significant progress in line with the recommendations.
Experts believe that Ukraine has implemented most of the FATF recommendations in its legislation. In addition, experts note that Ukraine is one of those countries that has established and strict rules and recommendations of international organizations and adheres to them, and this should be emphasized constantly.
In addition, the Cabinet of Ministers adopted a decree in 2021, which contains a plan until 2023 designed to further improve Ukraine’s score on certain recommendations.
2.5. Performance indicators of the SFMS
One of the important aspects of the SFMS’s activity is the formation and submission of summary materials to law enforcement agencies, which serve as the basis for criminal proceedings. It should be noted that the below-mentioned statistical data are generated on a regular basis. The investigation of certain cases can take years, and if the progress (referral to court, sentencing, etc.) took place in a particular year, it is included in the statistical information for that year. The SFMS constantly monitors the movement of summary materials provided by it. The basis of this data is information from law enforcement agencies. It should be noted that hundreds of summary materials are sent to law enforcement agencies every year. However, only some of them (28 in 2020, 9 in six months of 2021) are used by law enforcement agencies in the course of pre-trial investigation and formation of materials for referral to court.
The following statistical indicators characterize SFMS activity for 2019-2021:
A) Transferred materials by categories of financial operations:
Investigations into financial transactions involving suspicions of corruption
In 2019, the SFMS sent 211 summary materials related to suspicions of corruption to law enforcement agencies. For reference, in 2020, the figure was 204 summary materials, and during the first half of 2021 — 85.
Investigation of transactions related to budget assets
In 2019, the SFMS sent 45 summary materials related to budget assets to law enforcement agencies. For reference, in 2020, the figure was 64 summary materials, and during the first half of 2021 — 28.
B) The use of summary materials in criminal proceedings
According to law enforcement agencies, in 2019, 392 summary materials of the SFMS were used in 354 criminal proceedings during pre-trial investigations. In 2020, the figure was 328 materials in 314 proceedings, and in the first half of 2021—389 materials in 321 proceedings.
C) Completed criminal proceedings and their consequences:
According to law enforcement agencies, in 2019, 74 materials were sent to the judiciary in which summary materials of the SFMS were used. For reference, in 2020, the figure was 28 materials, and in the first half of 2021 — 9.
In 2019, the total value of seized and confiscated property (funds) in criminal proceedings based on the consideration of summary materials by the SFMS constitutes about EUR 170 million. For comparison, in 2020 the total cost was about 80 million euros.
In general, it should be emphasized that the summary material in itself is not evidence in criminal proceedings. Law enforcement officers need to recollect all the information from banking institutions, taking into account the information already received from the SFMS. In addition, the summary material contains data only on certain suspicious financial transactions. Therefore, it is necessary to obtain information on all accounts and transactions of the client. All this requires significant time and human resources. Experts note that this mechanism should be improved.
At the same time, there is also a problem with the lack of qualified personnel in law enforcement capable of working with summary materials at an adequate level. To address this, investigators need to receive constant training and the loss of talent should be prevented by resolving the reasons for staff turnover.
2.6. Training in the field of financial monitoring
Training in the field of financial monitoring is crucial. There is an Academy of Financial Monitoring under the FIU of Ukraine to strengthen the skills of SPFMs. One of the main tasks of the academy is to provide educational services on financial monitoring in the field of money laundering, as well as in the field of corruption prevention and counteraction. Experts note the proper quality of education at the academy.
In 2020, the Academy of Financial Monitoring trained 2,367 students:
728 — within the state order;
1639 — responsible officials of SPFMs.
According to the experts we interviewed, changes in legislation and the introduction of a risk-oriented approach in banks require a large number of qualified personnel who can cope with new challenges. At the same time, such personnel is currently insufficient, and it is necessary to constantly train SPFM employees to ensure the maximum efficiency of their work in financial monitoring. New experts in the field are only emerging.
Employees of the SFMS themselves receive advanced training through self-education, interdepartmental seminars, workshops, webinars organized by international organizations.
2.7. Movement of currency assets across the border of Ukraine. (statistics of declared cross-border cash transfers, detected undeclared cross-border money transfers, sanctions, etc.)
As mentioned above, a written declaration of cash is made in the case if the declared amount exceeds ten thousand euros. In the case of non-declaration, there is a liability in the form of a fine and confiscation of goods.
It is not possible to investigate the effectiveness of the cross-border cash declaration mechanism. On the one hand, experts note that there are problems with its application, which are related to the possibility of crossing the state border without declaring cash. On the other hand, public authorities note the existence of interaction (between the State Customs Service and the SFMS) in monitoring the cross-border movement of cash. This interaction is negatively affected by frequent reorganizations of the State Customs Service and the need to renegotiate information exchange agreements.
The State Customs Service provided the following statistical information:
1. Under Article 471 of the Customs Code of Ukraine:
1) protocols on violation of customs rules:
2019—2781, 2020—1785, 9 months of 2021—1534.
2) decisions issued by the court to impose an administrative penalty:
2019—2490, 2020—2139, 9 months of 2021—1238.
2. Under Article 472 of the Customs Code of Ukraine:
1) protocols on violation of customs rules:
2019—2057, 2020—1565, 9 months of 2021—1155.
2) decisions issued by the court to impose an administrative penalty:
2019—1101, 2020—1223, 9 months of 2021—986.
Note that the statistics provided relate to cases where the object of the offense was not only currency assets and cash but also other goods. No separate statistics are kept. This does not allow us to fully assess the effectiveness of the application of penalties for the non-declaration of currency assets.
During 9 months of 2021, customs seized foreign currency in 224 cases of violations of customs rules (including those provided for in Articles 471 and 472 of the Customs Code of Ukraine) for a total amount of over UAH 35.54 million.
According to the current case law, confiscation of currency assets is not used as punishment. In addition, the decision of the Constitutional Court of Ukraine declared the provisions of Article 471 of the Customs Code of Ukraine on confiscation of goods unconstitutional. Therefore, these articles shall be amended. The draft law has already been registered in the Parliament.

Practices

positive

negative

Promptly functioning financial intelligence unit with the necessary tools.
Adoption and implementation of a risk-oriented approach to the activities of banks as the main subjects of SPFM.
Adoption of a new progressive Law on Prevention and Counteraction.
Predominant compliance of the legislation of Ukraine with the MONEYVAL recommendations.
Active cooperation of SFMS within the country and with FIUs of foreign countries.
Accessibility of information on the activities of SFMS.
Lack of qualified personnel in law enforcement agencies that can promptly deal with generalized materials.
Different approaches to determining risk criteria in banking institutions.
Lack of automatic information exchange system in some banking institutions.
State evaluation will be published soon

In short

State of implementation

Legal framework

Legal framework after State evaluation.
Implementation in practice

Implementation in practice after State evaluation.

Practices

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negative

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Actual research and materials
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