A new report by the Global Initiative Against Transnational Organized Crime (GI-TOC) reveals how professional enablers operating within legitimate sectors help facilitate the laundering of criminal proceeds across the Western Balkans. Titled “Licence to launder: Professional money laundering enablers in the Western Balkans”, the report provides an in-depth examination of the role played by key designated non-financial businesses and professions such as notaries, lawyers, accountants and auditors in enabling illicit funds to enter and circulate within the formal economy.
Drawing on 89 interviews conducted across Albania, Bosnia and Herzegovina, Kosovo, Montenegro, North Macedonia, and Serbia, as well as extensive analysis of national risk assessments, legislation, and case studies, the report highlights how professional expertise and legal structures can be exploited to conceal the origins of criminal wealth. The report finds that while anti-money laundering (AML) frameworks across the region are broadly aligned with European Union and international standards, implementation remains weak. Fragmented supervision, limited enforcement, inadequate training and inconsistent reporting create vulnerabilities that professional money launderers and criminal networks are able to exploit.
The report also highlights significant concerns around underreporting by designated non-financial businesses and professions. In Montenegro, for example, notaries handled almost 20 000 property sales contracts worth approximately €1.6 billion in 2024, yet submitted only two suspicious transaction reports. The findings suggest that reporting by key professional sectors remains strikingly uneven across the region, raising concerns about whether suspicious activity is being adequately identified or simply going unreported. According to the report, real estate remains one of the most significant channels for laundering illicit proceeds. Property transactions, shell companies, nominee arrangements, fictitious invoicing and complex corporate structures are routinely used to obscure beneficial ownership and integrate illicit funds into the legitimate economy.
Professionals working at key legal and financial gateways often play a decisive role in providing an appearance of legitimacy to these transactions. “One of the most concerning findings is that money laundering increasingly relies on specialized professional services,” explains Anesa Agović Đozo, senior analyst at the GI-TOC’s Observatory of Illicit Economies in South Eastern Europe. “Professional enablers possess the knowledge, networks and credibility needed to navigate regulatory systems while shielding the true origins of illicit assets.” At the same time, the report notes that authorities have taken action in some cases. In Bosnia and Herzegovina, law enforcement operations led to charges against notaries, lawyers and local officials accused of facilitating illegal property registrations and money laundering schemes. The case demonstrates that professional facilitators are not beyond the reach of enforcement efforts, although such actions remain relatively rare compared to the scale of the risks identified. The report identifies notaries as particularly exposed to money laundering risks due to their central role in certifying property transactions. “Across the region, suspicious transaction reporting by designated non-financial businesses and professions remains very low, and in some cases almost absent, despite the scale of activity in high-risk sectors. Weak supervisory mechanisms, limited feedback from financial intelligence units and the use of professional secrecy as a reason for limited reporting further undermine the effectiveness of AML controls”, says Dardan Koçani, field coordinator for Kosovo at the GI-TOC’s Observatory of Illicit Economies in South Eastern Europe. The research also highlights the growing sophistication of money laundering schemes. Professional facilitators increasingly use cross-border corporate structures, offshore arrangements, cryptocurrencies, and complex financial instruments to move and conceal illicit funds. These arrangements often involve coordinated networks of lawyers, accountants, notaries, auditors and other intermediaries whose combined expertise creates multiple layers of legitimacy around criminal proceeds. The report calls for stronger oversight of designated non-financial businesses and professions, enhanced inter-agency cooperation, improved access to beneficial ownership information, and more effective sanctions for AML violations. It also stresses the need for specialized training, stronger risk-based supervision, and a cultural shift that places professional integrity and public interest obligations at the center of compliance efforts.