Guidelines on Risk-based Approach to Supervision: Money or Value Transfer Services (MVTS) in Montenegro

Chhina, Ramandeep Kaur

Guidelines on Risk-based Approach to Supervision: Money or Value Transfer Services (MVTS) in Montenegro

Chhina, Ramandeep Kaur

Authors

Ramandeep Kaur Chhina

Abstract

This Technical Paper aims to provide guidance to the national supervisory authorities to apply a risk-based AML/CFT supervisory approach to the supervision of the Money or Value Transfer Services (MVTS) sector in Montenegro. The objective of this paper is to strengthen the procedures for AML/CFT supervision of the MVTS sector in Montenegro by providing a guidance to supervisors on how to perform an overall ML/TF risk assessment with respect to their supervisory process and which factors should be taken into account.

The paper is based on a desk-based review of the relevant literature relating to the AML/CFT supervision of the MVTS sector (in Montenegro and internationally), as well as the information gathered during the interviews conducted with relevant stakeholders - the Central Bank of Montenegro and the Agency of Postal Services – about their current supervisory practices and challenges in the oversight of the MVTS sector in Montenegro. The relevant literature for the purposes of this paper includes, but is not limited to, the legislation and bylaws related to the supervision of MVTS sector in Montenegro (both governing the general supervision and AML/CFT specific supervision), 2015 National Risk Assessment Report of Montenegro, 2015 MONEYVAL Fourth Mutual Evaluation Report of Montenegro, risk-based approach guidelines issued by relevant authorities to the MVTS sector in Montenegro and internationally, sector-specific ML/TF typology reports published by international organisations such as the FATF (the global standard- setter for AML/CTF) and any other relevant literature on the operations and role of MVTS providers and their effective AML/CFT supervision.

The paper provides general findings and recommendations, in the form of guidance, to strengthen the risk-based approach in the AML/CFT supervision of the MVTS sector in Montenegro.