In cooperation with the Ministry of Justice and the Chamber of Notaries, the Council of Europe delivered a training course for notaries, as designated non-financial businesses and professions (DNFBPs) under the anti-money laundering and countering the financing of terrorism (AML/CFT) framework. The training session was held over two days, for two separate groups of notaries on 31 October and 1 November 2022. Additionally, a one-day workshop was organised on 3 November 2022 for representatives of the relevant supervisory and regulatory authorities, to provide guidance on effective AML/CFT supervision for the notaries’ sector. The events were hosted at the Academy of Justice of the Ministry of Justice – in charge of the supervision of notaries. The activities aimed to promote a clear understanding of AML/CFT compliance and supervision, in line with international standards and best practices in the notaries’ sector.
The training sessions designed for notaries contributed to strengthening their knowledge and capacities to better assess and understand money laundering and terrorist financing risks, successfully apply a risk-based approach, effectively allocate resources and mitigate such risks. The importance of ensuring a proper AML/CFT framework of internal policies, procedures and controls in place was highlighted throughout the training sessions.
Furthermore, notaries enhanced their understanding on how to effectively perform customer due diligence and identify beneficial owners. Discussions around complex, unusual behaviors which can be defined as red flags were important for notaries to increase their awareness on their role and obligations in the fight against money laundering and financing of terrorism. Best practices on how to detect, investigate, report, escalate and address such red flags when performing notary actions, in particular for the creation, operation and management of legal entities, or for buying and selling of real estate, were also shared with participants.
The back-to-back workshop for the notaries’ supervisory authorities featured similar topics, while also exploring the necessary control measures to be implemented by supervisors to enhance the effectiveness of compliance actions by notaries. Cooperation with the national Financial Intelligence Unit, other supervisors, other authorities, and registers were highlighted as essential pillars of effective AML/CFT supervision and compliance. Furthermore, through the workshop, the representatives of the Ministry of Justice, the Chamber of Notaries (in charge of developing and improving notary services) and the national Financial Monitoring Service, had an opportunity to share practices, discuss challenges and observe typologies and concrete cases in this sector. “Educating by supervising” emerged as a key message to be continuously promoted, with the aim to enhance the understanding by notaries of their AML/CFT obligations and potential ML/TF threats and vulnerabilities.
These activities were organised within the framework of the project “Strengthening anti-money laundering and asset recovery in Azerbaijan”, funded by the European Union and the Council of Europe and implemented by the Council of Europe in their Partnership for Good Governance II.
