SEE-Obs
SEE-Obs Hotspots IFFs in the Western Balkans Albania

Albania

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TOTAL population (2021)

2.81 million

corruption index 2023

37 / 100

CRIMINALITY SCORE

5.17

total area

28.8 km2

GDP total (2022)

US$18.88 billion

FREEDOM OF THE PRESS (2023)

57.86 / 100

RESILIENCE SCORE

5.13

GDP per capita (2022)

US$6 802.8

More about the Organized Crime Index

Introduction

According to the 2023 Global Organized Crime Index, Albania reduced its level of criminality by 0.46 points since 2021, the most significant reduction in any of the six countries in the Western Balkans. However, the country still has high-scoring criminal markets, including the cocaine and cannabis trade, financial crimes, cyber-dependent crimes, human smuggling and the heroin trade.

In Albania, based on trade-mispricing, illicit outflows are valued at 2.16% of GDP, while illicit inflows are valued at 0.84% of GDP. The 2020 GI-TOC report on illicit financial flows (IFFs) in Albania, Kosovo and North Macedonia revealed several crimes that generate IFFs in Albania, including the fact that drug trafficking has been the main profit centre for criminal groups in the country over the last 30 years; corruption is the second largest source of IFFs; and white-collar crime and tax evasion are also significant. Meanwhile, considerable amounts of cash are believed to enter Albania, primarily generated from the illicit activities of criminal organizations operating abroad.

Transparency International’s 2022 Corruption Perceptions Index places Albania at 101 out of 180 countries, with a score of 36 out of 100. Corruption remains a serious concern in the country and poses an overarching money laundering risk. The number of corruption investigations is increasing, but the final conviction rate remains low.

According to the 2021 Global Financial Integrity report, Albania’s mis-invoicing gap in global trade averaged US$904 million per year in 2009–2018, or about 6% of GDP. In addition, the informal economy remains a key challenge, estimated at almost 32% of GDP. Albania was placed on the Financial Action Task Force (FATF)’s grey list in February 2020, and delisted in October 2023. This came as result of progress made by Albanian authorities in improving the understanding of risk and institutional coordination and cooperation, mutual legal assistance, detection and prevention of criminal infiltration in the economy, beneficial ownership, prosecution and confiscation, and targeted financial sanctions.

Key challenges

  • IFFs are not defined in Albania, and the authorities have a reasonably good understanding of money laundering risks in the formal economy, but less attention is put on the role of the informal economy and trade.
  • Corruption poses major risks for IFFs in Albania. Often linked to organized crime activities, corruption generates substantial criminal proceeds.
  • Tax fraud is prevalent and forms a relevant part of the informal economy and money laundering activities.
  • Cash-based transactions and cross-border cash movement heavily undermine the formal economy.
  • Criminal control of legal entities poses high IFF risks for the private sector.
  • Money laundering investigations are generally initiated as a complementary measure of the main criminal offence and law enforcement agencies are not aware of money laundering as an autonomous activity or of IFFs moving through informal channels. Very few convictions have been secured for money laundering offences.
  • In 2023, there was an increase in confiscation of criminal proceeds, but there is still no strategic or systematic approach to identifying and confiscating criminal assets located abroad or not reachable.

Role of civil society

The role of civil society in tackling IFFs is important. This necessitates high-level political commitment to strengthen the effectiveness of measures to prevent and combat IFFs but also providing more space for civil society involvement in policy drafting and monitoring of measures related to IFFs.

In general, there is active civil society representation in Albania but it is sometimes limited due to funding constraints. This also limits civil society’s capacity to raise awareness of the impact of IFFs, advocate for policy changes and hold government and the private sector accountable for their actions. The Albanian government and donors should provide more funding opportunities and capacity-building support to civil society to increase their expertise in the area of IFFs.

Civil society, engaged citizens, non-profit organizations, journalists and academia all feed into efforts in combating IFFs. More specifically, civil society organizations can play a vital role in:

  • raising awareness about the negative impacts of IFFs on Albania’s development, governance and social welfare;
  • drafting risk assessments and policies, proposing solutions and contributing to evidence-based decision-making; and
  • advocating the adoption and inclusion of IFFs in the education curriculum, including through textbooks.
Immediate Outcome 1

Understanding the risk

Albania has a solid understanding of IFFs related to the formal economy, including commonly identified predicate offences. It has established a comprehensive anti-money laundering and counter-terrorism financing (AML/CFT) framework, characterized by legislative improvements through amendments to the AML/CFT Law in 2012, 2017 and December 2021. The country conducted National Risk Assessments (NRAs) in 2012, 2015, 2019 and, most recently, in 2023, coordinated by the Albanian financial intelligence agency (FIA). However, these assessments have not been made public. An abridged version of the 2019 NRA was placed on a specific FIA platform and can be accessed by reporting entities (such as banks, notaries and money transfers companies). In addition, in response to requests by civil society, an abridged version of the 2019 NRA has been made available to those that have requested it.

Supervisory authorities ensure that financial institutions and designated non-financial businesses comply with AML/CFT legislation, particularly in high-risk areas. Institutional policies are coordinated through bodies such as the Coordination Committee for the Fight against Money Laundering, which facilitates information exchange and cooperation.

However, understanding of the components of IFFs within the informal economy and trade system in Albania, as well as the role of tax evasion and the links between corruption and organized crime, remains limited. Corruption is a significant risk, generating substantial proceeds for IFFs, and the size of the informal economy, combined with the use of cash, increases vulnerabilities. The media play a crucial role in investigating and identifying IFFs, focusing in large part on activities in the construction and real estate sector, which represents a key risk for money laundering.

Also, there are areas where the policies and activities of authorities are not yet aligned with the risks. In order to mitigate money laundering and terrorist financing risks, further efforts (notably better coordination and deeper investigation) are needed to address more complex, holistic issues. This will be helped by:

  • increasing the number and quality of prosecutions of corruption-related money laundering cases;
  • stronger controls over cross-border cash movements;
  • finalizing the regularization of immovable property; and
  • risk-based supervision for all sectors
Immediate Outcome 2

International cooperation

The legal mechanism for sending and receiving mutual legal assistance requests is complex and involves various authorities with competing deadlines, causing delays in managing incoming requests. In addition, there seems to be no systematic prioritization of incoming mutual legal assistance requests and most entities involved in the process do not have a case management system in place. Delays in sending and receiving mutual legal assistance also stem from capacity constraints in law enforcement agencies, including personnel and other resources.

Unlike the other law enforcement agencies, Albania’s Special Prosecution Office seems much more efficient in terms of the time devoted to each case, as it is more specialized, deals with fewer but higher profile cases, and is a high-level institution with greater national and international support.

The 2018 Mutual Evaluation Report highlighted that a high incidence of Albanian criminal proceeds located overseas has resulted in a ‘remarkable number’ of mutual legal assistance requests being sent abroad. However, Albania has made progress in improving the timely handling of mutual legal assistance requests, as noted by the FATF in October 2023.

During 2022, the FIA sent 101 requests and spontaneous information to other financial intelligence units and in turn received 108 requests and spontaneous information. In 2021, it sent 82 requests and received 107, while in 2020 it sent 91 and received 113.

International cooperation on beneficial ownership data has been improved recently, since from June 2021 information on beneficial ownership information, legal persons and arrangements is made publicly available and can be obtained from the National Business Centre.

Immediate Outcome 3

Supervision

The key supervisory authorities are as follows:

  • Bank of Albania (BoA)
  • Financial Supervisory Authority (FSA)
  • Public Oversight Board (accountants and auditors)
  • National Chamber of Advocates (attorneys)
  • Justice ministry (notaries)

The BoA and the FSA require information during the licensing process to prevent convicted criminals and persons under criminal investigation from being the beneficial owner, having a controlling interest, or holding a management function in a bank or non-banking financial institution. The process for denying and revoking licences due to integrity concerns varies from sector to sector. Notaries are licensed by the justice ministry. The Law on Notaries does not allow individuals convicted of a criminal offence to obtain or maintain a notary licence, and this is strictly implemented.

The BoA has a good understanding of money laundering and terrorist financing risks in the banking and non-banking entities under its supervision, and coordinates with the FIA. Primary designated non-financial business supervisors show a basic awareness of the risks, while the Public Oversight Board has improved its understanding and issued a risk measurement methodology.

The BoA, the Public Oversight Board and the FIA have recently adopted a risk-based approach to supervision and have promoted capacity building in various prudential supervisors. Resource constraints hamper thorough inspections of all non-bank financial institutions, especially those in the money and value transfer, and currency exchange sectors.

The FSA and the BoA have signed a memorandum of understanding since 2005 to cooperate by exchanging information, conducting joint inspections and joint analysis in order to strengthen supervisory efforts and effectiveness. Every year, the FSA conducts a risk assessment of the AML/CFT risk exposure of entities required to submit self-assessment forms. The FSA exchanges information with the BoA for those entities that are licensed and supervised by both the FSA and the BoA.

The majority of remedial actions taken by the BoA and the FSA pursuant to breaches of AML and CFT obligations by reporting entities are limited to the application of recommendations.

Training efforts have raised awareness among banks, non-bank financial institutions and notaries, leading to improved compliance. Suspicious activity reports are submitted mainly by public notaries, the banking system and money transfer companies. An increasing number of suspicious activity reports (SARs) from public notaries was recorded in 2022. However, the number of cases submitted to the prosecution and the police decreased compared to previous years (2018–2021).

The 2023 MONEYVAL report emphasizes that the FIA and sectoral supervisors have made efforts to apply a risk-based approach to supervision of designated non-financial businesses. However, AML/CFT internal controls, policies and procedures are taken into account in the context of risk-based supervision only in relation to notaries and real-estate agents.

Immediate Outcome 4

Prevention

The spectrum of obliged entities responsible for AML/CFT includes banks or other entities licensed or supervised by the BoA, non-bank financial institutions, exchange offices, companies engaged in life insurance or reinsurance, attorneys, public notaries, accountants, independent auditors and real-estate agents. The legislative changes to the AML/CFT law in December 2021 included individuals engaged in transactions exceeding 1 million lek (around €9 000).

Banks have a good understanding of money laundering and terrorist financing risks and AML/CFT obligations, and apply mitigating measures in a manner that is mostly commensurate with the assessed level of risk. Banks conduct proactive assessments, including risk assessments on introducing new products or branch locations, and screening of walk-in customers against sanctions and politically exposed persons lists before initiating transactions. Since 2022, electronic fiscal reporting (fiscalization) is being applied, which enables for real-time declaration of business transactions.

Most reporting entities comply with customer due diligence and record-keeping requirements, although compliance is stronger among banking and financial institutions than among non-banking financial institutions. Banks largely identify and verify beneficial ownerships in accordance with these standards. Outside the banking sector, other financial institutions and the majority of designated non-financial businesses or professions rely on the National Business Centre as the sole source of beneficial ownership information. For example, the FSA has access to the register of benficial owners. Notaries have recognized their important gatekeeper role in real-estate transactions and have shown awareness of money laundering risks. Amendments to the law on notaries and a new law for the supervision of real estate agents were adopted in January 2022, as well as the necessary by-laws.

The implementation of AML/CFT obligations, including the identification of beneficial owners and the filing of suspicious transaction reports, has improved significantly in recent years. The 2023 MONEYVAL report emphasizes that the FIA and sectoral supervisors have made efforts to apply a risk-based approach to supervision of designated non-financial businesses. The data in the FIA’s 2022 annual report indicates that the agency covers a wide range of financial institutions and designated non-financial businesses and professions.

Immediate Outcome 5

Private sector

Information on the creation and types of legal persons and arrangements is publicly available through the National Business Centre and the District Court of Tirana, but there are concerns about the accuracy of this information. Information on beneficial ownership is also available through the National Business Centre and financial institutions as part of customer due diligence. However, Albania has not conducted an assessment of the money laundering and terrorist financing risks associated with different types of legal entities created in the country as part of its general understanding of the money laundering and terrorist financing risk assessment process (non-profit organizations aside, although even that assessment is outdated), and the understanding of the risks posed by legal entities is weak.

In 2020, the Albanian authorities conducted a risk assessment on the misuse for money laundering of legal entities registered in the country. This assessment was shared with stakeholders involved in the process and abridged versions were placed on a special FIA platform, which can be accessed by reporting entities. In addition, during 2023, the Albanian authorities were part of a project conducting a risk analysis on the cross-border risk of money laundering and terrorist financing of legal persons for Balkan countries.

Legal arrangements (e.g. trusts) are treated as high risk and require enhanced due diligence, but specific risk analysis has not been conducted. Despite legal requirements and customer due diligence, the authorities have limited capacity to monitor compliance and conduct inspections. According to the information available to Albanian authorities, legal arrangements have a negligible financial presence or financial footprint and therefore a specific fully fledged risk analysis is not warranted.

According to public perception and media investigations, the construction sector, tourism investments and grocery and food retail chains are vulnerable to misuse of money and associated with a high risk of facilitating IFFs. This includes money originating from criminal activities and organized crime, embezzlement of public funds, kickbacks and other corruption related to tenders and tax fraud. Despite arrests and trials, sentences have been limited and control over the establishment of legal entities by convicted individuals remains problematic.

A continued increase in real estate prices in a context of oversupply of stock – and local currency strength, which is not entirely explained by macroeconomic fundamentals – testify to the extent of illicit inflows of criminal proceeds into Albania’s economy. In effect, these flows represent the repatriation of illicit profits ‘earned’ by Albanian criminals abroad.

Immediate Outcome 6

Financial intelligence

The FIA is the central authority responsible for addressing potential money laundering and terrorist financing cases. It operates under the authority of the minister of finance, and has direct and indirect access to a wide range of information from state authorities and the private sector. The FIA receives SARs, cash transaction reports and information requests from law enforcement and intelligence institutions to develop financial intelligence.

In 2022, the FIA received an increased number of SARs and requests compared to previous years. However, the number of cases submitted to prosecution and police has decreased. It is therefore important to improve the quality rather than the number of SARs. The FIA disseminated cases to various institutions, including the police, the Prosecutor’s Office (including the Special Prosecution Office Against Corruption and Organized Crime) and the Secret Service. The FIA cooperates with other law enforcement agencies and uses its authority to access databases, such as the registries for driving licences, vehicles, immovable property, notaries, civil status and other public registries; the border police database; the register of convicted persons; cross-border declarations; tax data on legal entities; and the database of the assets and interest declarations of public officials of Albania.

The agency produces high-quality operational and strategic analysis to support the authorities in the investigation of money laundering, related predicate offences and preliminary investigations into terrorist financing. Its analytical process incorporates internal procedures, suspicious transaction reports, cash transaction reports, sectoral analysis, information from foreign counterparts and open-source data. The analytical staff are experienced and well trained, supported by effective information technology tools.

While cooperation between authorities is generally strong, improved feedback mechanisms between the FIA and reporting entities would enhance suspicious activity reporting. Similarly, regular feedback from law enforcement agencies to the FIA would help the agency to better support its operational functions.

Immediate Outcome 7

Investigations

Law enforcement agencies responsible for conducting financial investigations include the following:

  • General Directorate of State Police
  • Special Prosecutor’s Office
  • General Prosecutor’s Office
  • High Inspectorate of Declaration and Audit of Assets and Conflict of Interest
  • National Bureau of Investigation

At the policy level, based on the AML/CFT law, the Coordinating Committee of the Fight Against Money Laundering is responsible for determining the directions of the general state policy in the field of prevention and the fight against money laundering and financing of terrorism. A memorandum of understanding signed in 2020 between relevant institutions aims to improve effectiveness, but it lacks a clear national strategy and operational procedures.

Money laundering investigations often result in few indictments. Proceedings related to significant proceeds-generating offences are often suspended or dismissed. While the range of predicate offences is consistent with the country's risk profile, the number and type of money laundering cases do not reflect the level of underlying criminality.

Foreign predicate money laundering cases tend to rely heavily on evidence from foreign counterparts, while domestic cases lack robust circumstantial evidence. Law enforcement agencies rarely initiate standalone money laundering investigations – they often treat money laundering as an adjunct to criminal cases. The FIA claims to have adequately trained staff, but this is not the case for the General Prosecutor’s Office, which is hampered by a lack of trained personnel and adequate equipment.

Albania's investigation, prosecution and conviction of money laundering and high-level corruption cases are low and financial investigations need to be improved. Progress on asset seizures has improved, but actual confiscations remain low, despite a recent increase in 2022.

Immediate Outcome 8

Confiscation

The available statistics on seized and confiscated assets do not seem to be proportional to the level of criminality in the country. The non-conviction confiscation regime of the Anti-Mafia Law is applied more often than the mandatory criminal confiscation regime, which typically allows only for the confiscation of criminal tools, and not the proceeds. Although parallel financial investigations are systematically applied, the effectiveness of this system is poor.

Albania has legislation that allows for the social reuse of confiscated assets, and in particular has established a dedicated fund for crime prevention, which uses funds from confiscated assets for state and community crime prevention initiatives, and legal education projects.

According to the FIA’s 2022 report, €16 million of assets were seized in the last five years based on a freezing order originally issued by the FIA, including €2.4 million in 2022, but information on confiscations is lacking. The General Directorate of Customs identified 36 cases of cash transportation in 2021, with a value totalling around €1.8 million, but details on further proceedings or confiscations were unclear. The strengthening of the national currency (lek) since 2014, peaking at 20% in 2022, is attributed by the Bank of Albania to formal macroeconomic factors, but some media and civil society sources link it to the influence of IFFs in the economy, which cannot be explained by economic factors alone.

Immediate Outcome 10

Non-profit organizations
in the prevention of IFFs

Albania has had an anti-terrorist financing law in place since 2013, which was updated in 2019 to meet UN requirements for implementing financial sanctions against terrorist financing. The amendments establish clear national procedures for proposing designations to UN Security Council (UNSC) committees and for requesting foreign countries to implement freezing measures. Targeted financial sanctions are implemented promptly.

The country has a domestic designation system that is aligned with UNSC Resolution 1373 and foreign requests, but has not proposed any individuals for UNSC designation. Albania assesses its risk of terrorist financing ‘low’ due to minimal terrorist threats.

The 2019 and 2023 NRAs have considered the risk deriving from terrorist financing differently from the risk of money laundering. Although intelligence and law enforcement agencies are active in countering terrorism and applying enhanced due diligence, their understanding of financing risks is lacking.

In 2019, in cooperation with the FIA, the General Directorate of Taxes, as a supervisory body of non-profit organizations, developed a methodology for the identification of non-profit organizations with a risk of terrorist financing. This methodology identified specific criteria that can serve as a basis for a risk-based approach to supervision.

A risk assessment for non-profit organizations was conducted in 2022 by Partners Albania for Change and Development, which showed minimal impact of terrorism in the country. Although Albania has established a framework for risk-based supervision of non-profits, it remains tax focused.

Regarding proliferation of weapons of mass destruction, Albania is partially complying with UN Security Council resolutions.

Recommendations
for policymakers

  • Review the reasons behind the poor performance in terms of the prosecution of money laundering cases and address in the next national risk assessment shortcomings identified in the investigative process.
  • Enhance the analysis of money laundering and terrorist financing risks to implement appropriate mitigation measures, most notably by way of understanding the impact of the informal economy and of corruption (including its nexus with organized crime) on money laundering and terrorist financing risks;
  • Pursue more indictments in money laundering cases involving foreign proceeds, partly by making better use of circumstantial evidence concerning the predicate crimes committed.
  • Ensure that adequate efforts are made to identify criminal proceeds located abroad and take appropriate actions for their confiscation.
  • Ensure adequate measures are in place to initiate financial investigations in a systematic manner in all proceedings involving assets derived from organized and other sorts of serious crimes within the scope of the Anti-Mafia Law.
  • Ensure the implementation of high standards by supervisory authorities in licensing or other controls to prevent criminal infiltration of financial institutions and designated non-financial businesses or professions. This should include a comprehensive framework of screening applicants, indirect shareholders and beneficial ownerships; assessing criminal records beyond criminal convictions and current proceedings, and potential links to criminal associates; obtaining international cooperation whenever appropriate; and implementation of ongoing mechanisms to check the integrity of existing licences.
  • The FIA’s resources for supervising private entities should be further strengthened.
  • The FIA should provide more regular feedback to reporting entities on specific suspicious activity report filings to further improve reporting behaviour and the quality of suspicious activity reports.

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