Consultations on combating money laundering in cooperation with the Kosovo Prime Minister's Office

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Published: May 21, 2024

In cooperation with the Office of the Prime Minister of Kosovo, IRZ was involved in an advisory project on combating money laundering in Kosovo from November 2022 to the end of 2023. The Federal Foreign Office financed the project.

The consultations focused on a comprehensive analysis of the legal and institutional framework for combating money laundering in Kosovo, with a particular focus on the general conditions for effectively combating money laundering as well as the legal framework of criminal money laundering law and asset recovery. Based on this analysis, a report with concrete and practical recommendations for action was submitted to the Kosovo Prime Minister's Office in November 2023.

The report was written by a team of three experts: Dr Stefan Trunk, Senior Public Prosecutor at the Duisburg Public Prosecutor's Office and Chairman of the Examination Commission at the Düsseldorf Higher Regional Court, Prof Dr Mohamad El-Ghazi, Professor of German and European Criminal Law, Criminal Procedure Law and Commercial Criminal Law at the University of Trier and Director of the Trier Institute for Money Laundering and Corruption Criminal Law (TrIGeko), and Mr Thomas Seidel, former police officer in the Federal Criminal Police Office and the Financial Intelligence Unit (FIU), Senior Compliance Officer in universal banks, lecturer in anti-money laundering and founder of the non-profit organisation antifinancialcrime.org gGmbH.

In addition to the document-based assessment of the legal framework, the team of experts travelled to Pristina three times within a year to hold in-depth expert discussions with representatives of a total of fifteen Kosovan and international institutions. In addition to a meeting with Prime Minister Albin Kurti in March 2023, working visits were made to the Special Prosecutor's Office, the General Prosecutor's Office, the Court of Appeal, the FIU, the police, the Central Bank and the customs authority, among others. In addition, two cross-institutional roundtables were organised to discuss challenges and discrepancies in the interpretation and application of the law in practice.

Another integral part of the project included the organisation of training events in the area of money laundering investigations related to crypto-assets. In this context, a 15-member delegation – mainly representatives from Kosovan public prosecutors' offices, police authorities, the FIU and the central bank – travelled to Germany in December 2023 and hold working discussions with German institutions, including the German Federal Financial Supervisory Authority (BaFin) in Frankfurt, the Central Office for Financial Transaction Investigations – Financial Intelligence Unit in Cologne, the Central and Contact Point Cybercrime North Rhine-Westphalia (ZAC) of the Public Prosecutor General's Office in Cologne, the Central Office for Combating Cybercrime (ZIT) of the Public Prosecutor General's Office in Frankfurt and the Federal Criminal Police Office in Wiesbaden.

Despite the high priority that the current Kosovan government attaches to combating money laundering and corruption, the EU Commission's latest progress report from November 2023 once again denounces the urgent need to reform the Kosovan law on combating money laundering and terrorist financing. The analyses of the team of experts and the recommendations for action derived from them can make an important contribution to aligning Kosovan legislation with the EU acquis and international standards, while at the same time strengthening the efficiency of investigative structures and promoting more effective application of the law by Kosovan law enforcement and judicial authorities.

Further information on the project can be found in the March 2024 issue of the Journal on Legal and Economic Development in the Countries of Central and Eastern Europe (WiRO).