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06 April 2020

Activity Details (ID# 32735)  

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Title Capacities of the APML 
Description Activity 3.2- Study visits:
a) Study Visit No.1 to UK- (11-14 July 2011), Study visit costs.
b) Study Visit No.2 ''AML/CTF Standards in the Baltics'' Tallinn and Vilnius, 22-25 November 2011

Activity 3.3 - Train the analytical staff od the FIUs on analysis and exchange of financial information and provide translated and published complilation of FATF typologies into Serbian language

- Attending Octopus conference, Strasbourg, France, 21-23 November 2011

Status Completed 
Date 01/01/2011 - 31/12/2011 
Location Serbia
Countries CoE Members: Serbia
  Joint Programme Activity - Serbia-MOLI
Joint Programme EC/CoE
JP Serbia-MOLI - Project against Money Laundering and Terrorist Financing and Economic Crime in Serbia    (Logframe)  (Activities)
Project Purpose 1 - 2010/DGHL/JP/2274   Project against Money Laundering and Terrorist Financing and Economic Crime in Serbia
Expected Result 1.3 - Capacities of the APML to carry out its duties in line with the implementation of the AML/CTF legislation and Moneyval recommendations is increased
Council of Europe Programme of Activities
I – Rule of Law
Line of Action ⇒ II.3 – Countering Threats to the Rule of Law
Programme ☆ II.3.2  Organised crime and terrorism

Working Method

Directorate Human Rights and Legal Affairs 
CoE Contact ,   email
Last Modified 01/03/2012 

Activity Synopsis (ID# 32735) (Hide Synopsis)

Objective(s) Capacities of the APML to carry out its work in line with the AML/CFT legislation and Moneyval Recommendations is increased. 
Output/Results 1) Study visit to the Serious Organised Crime Agency (SOCA), Financial Services Authority (FSA), and the Gambling Commission, in London, UK, from 11-14 July 2011:

MOLI Serbia project undertook a study visit on the “Implementation of AML/CTF Standards in the United Kingdom”. Why the UK was chosen? There are very few countries that have taken a National Risk Assessment to any degree and it is believed none in Europe have. However, the UK does have considerable experience in producing an Organised Crime Threat Assessment and has very able and experienced strategic analysts, something that Serbia does not have and would like to have. As it is the process of analysis that is most important discussions with analysts to draw on their experiences was of great benefit to the Serbian delegation. Secondly, although the FIU system is different in both countries it was useful for the delegation to understand how the relationship between FIU and investigators is managed in relation to the STR system in the UK. In addition, the UK FIU has been subject to a number of reviews and amendments over the years and this is something that has not yet been undertaken in Serbia. As the system there has now been established for nearly 10 years it is perhaps time for them to be thinking about this, especially with the prospect of EU Accession in mind. There is a system of AML supervision by the National Bank of Serbia for the banking sector and in general it works fairly well despite some criticism from Moneyval as to effectiveness. There is however a lack of experience in the supervision of the Insurance Sector, Voluntary Pension Funds, and Leasing Companies, and other NFBPs and the group took the opportunity to talk with a financial services regulator and to learn from their experiences and practices with these sectors. Whilst the casino industry is not that extensive in Serbia it does exist and there are fears that it will grow substantially with the involvement of organised crime. The APML have recently agreed to assist the Games of Chance Directorate of the Ministry of Finance in the supervision of the casinos for AML/CFT purposes but as yet there is no experience of undertaking this type of inspection and they would therefore be very interested in drawing on the experience of the UK authorities.

The 10 member group consisted of representatives from the Administration against Money Laundering in Serbia (APML), the National Bank of Serbia, the Ministry of the Interior and the Prosecutor’s Office. The participants were given presentations by representatives from the Serious Organised Crime Agency (SOCA), the Financial Services Authority (FSA) and the UK Gambling Commission. Special attention was given to good practices in carrying out the National Risk Assessments and combating the financing of terrorism.

The Serbian delegation had an opportunity to see how the UK system operates in practice, what are the strong points and shortcomings in various sectors. The delegation was interested in various approaches, from making suspicious activity reports and creating a central database that would be used by all stakeholders in the system, to particularities and experiences in producing a national risk assessment.
Following each presentation, there were a few key points in which the members of the delegation were particularly interested:
 how to set up agencies to operate in partnership and provide a smooth flow of information and effective channels of communication;
 what types of specialist services could be applicable in the Serbian system;
 how to enhance and raise the degree of efficiency of the suspicious activity reports;
 what are the key steps in producing a national risk assessment, and how to involve multiple public sector office;
 UK’s experiences with implementing particular pieces of legislation in the gambling business.

2) Organise 1 study visit for Customs / Police to a European jurisdiction that is specialized on the use of cash detection dogs.

The MOLI project team held meetings with Customs Administration on 1 June and 22 June 2011. The Assistant Director of Customs Administration in Serbia and the French Customs Attaché for the Balkans region participated in meetings. The purpose of these meetings was to discuss the arrangements and content of the study visit to the French Customs for three Serbian Customs officials. The three officials were selected from two different units (Anti-Smuggling Department and Procurement Department) with the aim of learning about the best practices in setting up and running a canine unit. As a result of this study visit, the Serbian Customs are now equipped to set up a canine unit and develop it accordingly, with a plan to develop teams of dog handlers and dogs trained for cash detection.

2. Study visit to French Customs Directorate-General in Paris and the National School for Customs Officers in La Rochelle. (26-36 September 2011)

From 26 to 30 September 2011, MOLI project organised a 5-day study visit to French Customs Directorate-General in Paris and the National School for Customs Officers in La Rochelle. The three officials were selected from the Anti-Smuggling and Procurement departments of the Serbian Customs and have been trained in how to organise a canine unit, especially regarding budget planning and human resources management. The Customs’ officers were also given several practical demonstrations of dogs trained to detect narcotics and explosives at Orly Airport and Gare du Nord train station in Paris.

Serbian Customs have arranged to send two officers for dog-handling training for the next training session at the French National School for Customs Officers in La Rochelle (May 2012). This training will be financed independently of the MOLI project. However, the project will be involved in further training specific to the cash detection once the canine unit is operational.

Conclusions/Follow Up 1) The first of three study visits has been completed (UK). 10 persons undertook study visit. Report on study visit has been produced. The Republic of Serbia has already signed the Memorandum of Understanding with the UK.

2) Study visit organised to the Canine Unit in France and the Study Visit Report has been produced. The Activity has been completed. 
CoE Secretariat  
Total No. Participants 15 
Last Modified


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