As part of its efforts aimed at enhancing the risk-based approach to Anti-Money Laundering and Countering Financing of Terrorism (AML/CFT) supervision of the financial sector in Croatia, the Council of Europe’s Economic Crime and Cooperation Division (ECCD) has been supporting the Croatian National Bank (CNB) and the Croatian Financial Services Supervisory Agency (Hanfa) with enhancing their data collection tools. 

In this regard, the ECCD has previously supported both institutions with comprehensive reviews of annual questionnaires submitted to obliged entities under their supervision. The reviews were accompanied by a number of recommendations aimed at enhancing the quality of the data to be collected, most notably as regards inherent risks and the effectiveness of controls used by obliged entities to detect and prevent financial crime.  

Following a complete revision and update of questionnaires undertaken by both Hanfa and CNB, the project has conducted a second expert review in June 2023, in order to identify any outstanding issues and final improvements to be made. The results of the review were presented and discussed with CNB and Hanfa representatives during consultative meetings held in Zagreb on 5-6 June 2023. 

The meetings provided the opportunity to further reflect and brainstorm on the formulation of some questions which were ambiguous as regards the expected input. Based on expert advice, some of the questions have thus been amended in order to better reflect the existing ML/TF risks and typologies encountered in Croatia.

The events were organised within the framework of the Technical Support Instrument initiative “Risk-Based Supervision of Anti-Money Laundering and Countering the Financing of Terrorism in Croatia”, funded by the European Commission’s Directorate General for Structural Reform Support (DG REFORM) and the Council of Europe and implemented by the Council of Europe.