Edited by Joseph Malvisini

Moneyval presented its final report for the programme which ended in 2022 and at the same time, in Warsaw on 25 April, highlighted the action plan envisaged for the following years.
2023 – 2027.

This document, which we will discuss in its essential aspects, represents Europe's "positioning" regarding anti-money laundering issues for the coming years.

Let us now move on to the analysis of the document.

The plan, starting from an assessment according to the SWOT logic (analysis of the strengths, weaknesses, opportunities and threats of the anti-money laundering prevention system of the member countries), saw, in its formulation, the participation of former presidents, executive secretaries and experts of the same organization.

Moneyval observes that the risk of money laundering and terrorist financing are ever-expanding phenomena, taking on an increasingly international and/or transnational character, with estimates putting the total amount of money laundering worldwide at between $500 billion and $1 trillion.

The financing of terrorism remains the basis for all forms of organizational and propaganda assistance in the "selection" and proselytism activities. It is the primary threat to the security of the world's populations.

To respond to these threats, the FATF developed the international standards we know well, which have translated into 40 recommendations that have become a guideline and inspiration for countries around the world.

Conversely, it is the FATF system itself, and specifically within the European Union (Moneyval), that verifies the effectiveness of the methodology for applying the recommendations, ensuring they are correctly translated and applied in different national contexts. To this end, it is worth noting that Italy was the subject of a specific review at the end of 2021, the results of which, regarding the application of the Fourth EU Directive, identified significant areas for improvement.

Indeed, in the broader European context, it is important to note how areas for intervention have been identified in the supervision of the financial sector, the low levels of compliance in the private sector, the lack of transparency in the structures of legal entities, and the limited convictions and confiscations for money laundering offenses. Last but not least, the lack of sanctions for terrorist financing and the proliferation of weapons of mass destruction. International cooperation and the value of the Financial Intelligence Units of various countries are recognized strengths.  

The 2023-2027 strategy aims to increase Moneyval's contribution to developing and improving the effectiveness of prevention systems at the national, regional, and global levels, a key aspect of its mission since its inception. This effort will necessarily need to be developed over the course of several years.

The implementation of the plan is based on a series of “pillars”.

Pillar No. 1: Continue and strengthen monitoring of anti-money laundering activities in participating countries through "reciprocity assessments"

In this logic, it will complete the fifth cycle of evaluations, of which 4 in 2023 and the remaining 3 during 2024.

Some useful elements for the concrete realization of the first "pillar":

• Greater emphasis on disseminating a culture of combating money laundering through action aimed at strengthening political awareness in states and territories focused on the implications of the mutual evaluation process.
• Strictly apply the FATF methodology.
• Improve the quality of follow-up evaluation processes.
• Evaluate the extensibility of statistical criteria and parameters acquired with the fifth evaluation cycle in order to create elements of comparability between the fifth and sixth evaluation cycles with the aim of defining key quantitative indicators (with regard to conviction outcomes, recovery of seized assets and international cooperation, taking due account of the relevance of national jurisdiction and considering individual specificities).
• Implement a comprehensive evaluator training program in 2024–2027 to upgrade the pool of evaluators, based on strengthened quality standards.

Pillar 2: Expanding the role of Moneyval as a point of reference for defining a Europe-wide money laundering risk.

In its activities, Moneyval has largely focused on country-by-country monitoring and has not yet attempted to explore trends or risks within the "Europe Region." Given the transnational nature of money laundering, developing a holistic understanding of these trends, encompassing a broader framework than a single national perspective, is essential for effective AML/CFT strategies. Such an assessment has never been carried out.

Pillar 3: Develop Moneyval's role in its relations with the FATF and other regional organizations.

To achieve the above-mentioned goal, it is essential to create a more effective exchange system between the FATF and Moneyval. The FATF oversees and reviews the outcomes of the reports and provides regulatory interpretations, while Moneyval participates in projects and provides analysis and commentary on the FATF's reports.

While the relationship in the first case is clear, Moneyval must, on the other hand, more independently strengthen its prestige in its relationships with regional bodies assessing and coordinating money laundering risks. Initial results of this effort have been seen in the exchange programs for assessors and the development of a single feedback system for assessment outcomes.

Pillar 4: Developing synergies within the European Council

The President of Moneyval participates in an annual communication exchange with the Secretary General of the Council of Europe, with the involvement of the Presidents of other Council of Europe monitoring bodies. This provides the opportunity to address highly relevant issues and develop cross-cutting tools for intervention at the Council of Europe level.

However, potential synergies on issues of common interest, interconnected with AML issues, such as human trafficking, corruption, and drug trafficking, must be further exploited.

Pillar 5: Developing a political role for Moneyval with its own media visibility.

Moneyval's political engagement and media visibility have increased, including through targeted media engagement. The Committee of Ministers of the Council of Europe and the Parliamentary Assembly are increasingly interested in Moneyval's issues and operations. 
Furthermore, the practice of including high-level government representatives and ministers in an exchange of views with the Moneyval president at the beginning of the evaluation process increased political visibility and ensured crucial high-level political support.

Pillar 6: Moneyval Resources.

Moneyval's resources, coming from the ordinary budget, will enable the achievement of all the objectives defined in the strategy. Funding will be made available on a voluntary basis to Member States and territories participating in Moneyval.

What can we say? It's a challenging project, so all we can do is wish Moneyval: "Good luck."