Serbia updates its understanding of risk in various areas

01 October 2021

On 30 September 2021 Serbian Government adopted the ML NRA and TF NRA updates, ML and TF Risk Assessment for VA and VASPs, and Risk Assessment for the WMD Proliferation Financing.


The risk assessments cover the period of three years (1 January 2018 – 31 December 2020).


Given the relevance of proliferation financing and virtual assets-related issues, this is the first time Serbia did a separate risk assessments for these two areas.


Having coordinated the first two NRAs (in 2012 and 2018) Ms Jelena Pantelić of the APML also coordinated the entire the 2021 NRA process and chaired the main Working Group, appointed by the Government of Serbia.


The NRA Working Group also comprised the representatives of the Republic Public Prosecutor’s Office, Prosecutor’s Office for Organised Crime, Ministry of the Interior, Security-Information Agency, Office of the National Security Council and Classified Information Protection, Ministry of Justice, Adminstration for the Prevention of Money Laundering, National Bank of Serbia and Securities Commission. The Working Group operated through the following subgroups, which were coordinated by representatives of various AML/CFT institutions:

1. Threats to the system (Mr Miljko Radisavljević, Deputy Prosecutor, Republic Public Prosecutor’s Office, and Ms Jasmina Milanović Ganić, Deputy Prosecutor for Organized Crime);
2. Vulnerability of the national system (Ms Marijana Simić Vujašević, Senior Advisor, Prosecutor’s Office for Organised Crime);
3. Financial system vulnerability and risk assessment in the VA/VASP area (Mr Marko Marinković, Director of AML Center, National Bank of Serbia and Mr Goran Kuprešanin, Senior Advisor, Securities Commission);
4. DNFBP sector vulnerability (Ms Danijela Tanić Zafirović, Senior Advisor, Administration for the Prevention of Money Laundering);
5. Terrorist Financing and WMD Proliferation Risk Assessment (Mr Vladimir Stevanović, Senior Advisor, Prosecutor’s Office for Organized Crime and Ms Sanja Dašić, Senior Advisor, Office of the National Security Council and Classified Information Protection).


The risk assessments were conducted using the World Bank Methodology, methodologies of the Council of Europe and RUSI (Royal United Services Institute for Defence and Security Studies), as well as Serbia’s own methodology, which is based on professional experience and lessons learned from previous NRA rounds. The risk assessments saw the participation of hundreds of participants from the public and private sectors, which helped the authorities make an objective examination and analysis of all potential risks.