COUNTRY UPDATE – Serbia AML 2024
(Contribution by Suzana Pavlovic, Attorney at Law in Rokas Belgrade, published in Thomson Reuters, Regulatory Intelligence, Country update – Serbia: AML, July 2024)
The article by Suzana Pavlovic provides a detailed overview of Serbia’s legislative measures to prevent money laundering and terrorism financing. It outlines the main laws, responsible authorities, and Serbia’s international cooperation efforts.
Key Legislation The primary law is the “Law on Prevention of Money Laundering and the Financing of Terrorism,” last amended in 2023. This law defines money laundering and terrorism financing and lists entities (banks, notaries, lawyers, etc.) required to comply with its provisions. It mandates various preventive measures, such as customer due diligence, monitoring, internal controls, and risk assessments.
Authorities and Supervision The Administration for the Prevention of Money Laundering, part of the Ministry of Finance, is the key authority. It collects and analyzes data, and can temporarily suspend transactions suspected of involving money laundering or terrorism financing. Other supervisory bodies include the National Bank of Serbia and various ministries.
Penalties The law prescribes penalties for non-compliance, with fines up to 3,000,000 RSD for legal entities and 200,000 RSD for responsible individuals. There are also specific fines for misdemeanors.
Additional Legislation The “Law on Freezing of Assets” targets terrorism and weapons proliferation, mandating asset freezes for designated individuals and entities. The “Strategy for Prevention of Money Laundering and Financing of Terrorism” outlines goals and actions for 2020-2024, aiming to strengthen Serbia’s financial integrity and legal compliance.
International Cooperation Serbia actively participates in international efforts, being a member of MONEYVAL and the EGMONT Group, and has agreements like FATCA with the United States. It also collaborates with neighboring countries’ financial intelligence units.
Challenges and Improvements Despite a robust legal framework, Serbia faces implementation challenges. The 2023 Annual Report highlights irregularities among obligated entities, especially in risk analysis and internal controls. Strengthening supervision and enforcement is crucial to maintaining financial system integrity and international compliance.
Conclusion Serbia’s legislative and cooperative measures form a comprehensive approach to combating money laundering and terrorism financing. Ongoing efforts to enhance supervision and enforcement are essential for sustained regulatory compliance and financial transparency.
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