GI-TOC ¦ Licence to Launder: How Professional Enablers Sustain Illicit Finance in the Western Balkans

A system built on trust and exploited through expertise

Professional money laundering is not a fringe problem in the Western Balkans. It is a structural feature of how illicit money enters, moves through, and is embedded in the formal economy. A new report by the Global Initiative Against Transnational Organized Crime shows that notaries, lawyers, accountants, auditors, real estate brokers, and other professional intermediaries can be drawn into laundering schemes not simply through ignorance, but also through weak oversight, fragmented regulation, and selective use of professional secrecy.

The central insight is stark: the region already has anti-money laundering rules on the books, often aligned with EU and FATF standards, yet those rules are not being enforced with enough consistency or force to stop professional enablers. In practice, compliance is too often reduced to paperwork, while suspicious transactions pass through legal and financial channels with little scrutiny.

Professional enablers as the hidden layer of laundering

The report describes professional money launderers as individuals or networks that provide laundering services for a fee. They do not need to be tied to one criminal group or one predicate offence. They may serve multiple clients across sectors and borders, using legal and financial knowledge to make illicit funds appear legitimate.

Their role is especially important because they sit at the junction of legality and concealment. They can establish companies, draft contracts, notarize property transactions, manage records, prepare accounts, and structure ownership in ways that obscure the source of funds. The result is not always blatant criminality in the traditional sense. More often, it is a veneer of legitimacy – a transaction that looks legal on paper but is built to disguise illicit wealth.

Bastian Schwind-Wagner _Follow

"The report shows how professional enablers in the Western Balkans help illicit money move through legal and financial systems by using their expertise, formal authority, and weak points in supervision. Notaries, lawyers, accountants, auditors, and real estate intermediaries are often central to these schemes, especially in property transactions and company structures.

The main problem is not a lack of laws, but weak enforcement, limited supervision, and poor coordination between institutions. Stronger risk-based oversight, clearer reporting rules, and better feedback from FIUs are needed to reduce the space for professional money laundering."

Why notaries matter so much

Among the professions examined in the report, notaries stand out as particularly exposed. In much of the Western Balkans, property sales and other significant transactions must be certified by notaries, which gives them a central gatekeeping role. That position makes them valuable for anti-money laundering efforts, but also attractive to criminals seeking legal validation.

The report shows that notaries are often involved in transactions where property values are manipulated, ownership changes rapidly, or cash side-payments sit outside formal contracts. These cases can involve undervalued sales, inflated contracts, nominee ownership, sham loans, or the legalization of illegal construction. When supervision is weak, the notarial seal can become a tool for laundering rather than a safeguard against it.

The reporting record is uneven. Some countries, such as Albania and Serbia, show higher numbers of suspicious transaction reports from notaries, while others, such as Montenegro, record very low numbers compared with the volume of transactions handled. That gap is one of the clearest signs that formal obligations are not translating into risk-based practice.

Lawyers and the misuse of confidentiality

Lawyers occupy a different position in the laundering chain. They are not public certifiers like notaries, but they often structure the legal arrangements that allow illicit funds to circulate. They may create companies, draft loan agreements, manage client funds, or act in property and business transactions. These are normal legal services, but they can be misused to create distance between criminals and their assets.

The report highlights a recurring problem: the overbroad use of professional secrecy as a reason not to report suspicious activity. In some jurisdictions, lawyers appear to treat confidentiality as if it were absolute, even though AML obligations still apply when legal services are used to facilitate transactions outside the narrow scope of courtroom defence and legal advice. This is one of the most important blind spots in the region. It weakens reporting, narrows supervision, and creates a safe space for illicit finance.

Accountants and auditors as financial narrators

Accountants and auditors are not primarily transaction handlers, but they are essential to the construction of plausible financial stories. They prepare books, accounts, invoices, tax filings, and financial statements that can either expose or conceal irregularities. Criminal networks know this, and they use those services to fabricate business activity, support false invoicing, or maintain shell companies.

The report finds that accountants are among the least active reporting entities in much of the region, with Serbia being the main exception. In several countries, no suspicious transaction reports were filed by accountants over multi-year periods. That does not necessarily mean the sector is clean. It more likely signals weak awareness, poor supervision, and limited willingness to challenge clients.

Auditors face similar risks. Their work can validate manipulated financial statements and obscure the fact that a company is serving as a laundering vehicle. Yet oversight of auditors is often light, and enforcement outcomes remain rare. When inspections focus on form rather than substance, auditors may satisfy checklists without identifying the underlying risks.

Real estate as the main entry point

One of the report’s strongest findings is the central role of real estate. Property remains one of the easiest ways to convert illicit cash into legitimate-looking wealth. It is tangible, easy to overvalue or undervalue, and often supported by professional documentation that creates a lawful appearance.

Across the Western Balkans, real estate transactions are repeatedly associated with laundering techniques such as rapid resales, inflated or deflated sale prices, nominee purchases, and fake loan contracts. In Bosnia and Herzegovina, the Federation remains a major blind spot because notarization is not mandatory for property sales, unlike in Republika Srpska and Brčko District. That legal difference creates room for professional enablers to move illicit funds with less oversight.

In Serbia, illegal construction and property regularization continue to be major channels for integration. In North Macedonia, legalizing informal buildings has become a recurring risk. In Montenegro and Albania, coastal real estate in particular has drawn concern because of foreign cash purchases and offshore-linked buyers. The pattern is consistent: property is where illicit money often becomes visibly legitimate.

Networks, not isolated actors

The report is careful to show that laundering is rarely the work of one person. More often, it is a networked process in which each professional performs a distinct role. Lawyers build structures, accountants prepare the financial narrative, notaries certify the documents, and real estate brokers connect buyers and sellers. Criminal clients may never need to meet the full network. Each layer adds credibility and distance.

This division of labour makes detection harder. No single participant may know the full scheme, or each may claim to have merely performed a routine professional task. That is precisely why the report argues for intelligence-led supervision, better data sharing, and stronger feedback loops between FIUs and the professional sectors.

The real problem is not the law, but implementation

A major theme of the report is that the Western Balkans do not suffer from a complete absence of AML law. The real weakness lies in enforcement, supervision, and coordination. Professional chambers often lack the authority or capacity to conduct meaningful AML inspections. FIUs may receive suspicious transaction reports but rarely provide useful feedback. Inter-agency cooperation is fragmented. Databases are incomplete. Sanctions are rare.

As a result, many professionals comply in a defensive way. They file reports to avoid penalties, not because they have internalized the risk. Others simply avoid reporting at all, relying on uncertainty around professional secrecy or the absence of visible consequences. In that environment, money launderers do not need perfect secrecy. They only need weak friction.

What needs to change

The report calls for more than legislative alignment. It argues for stronger supervision, clearer rules on secrecy and privilege, better beneficial ownership transparency, more serious training, and structured feedback from FIUs to reporting professions. It also recommends fit-and-proper checks for DNFBPs, risk-based inspections, stronger sanctions, and annual public reporting on AML compliance by professional bodies.

Those measures matter because professional enablers are not a side issue. They are one of the main reasons illicit finance can survive inside legitimate economies. Without tighter controls on the professions that authenticate, structure, and narrate financial activity, criminal money will continue to move with quiet efficiency through the region.

Conclusion

The Western Balkans has built a compliance architecture that looks stronger on paper than it is in practice. The report shows how that gap is exploited by professional money laundering networks that depend on legal expertise, financial know-how, and institutional weakness. Notaries, lawyers, accountants, auditors, and real estate intermediaries are not the only reason illicit finance thrives, but they are often the point at which dirty money becomes hard to distinguish from ordinary commerce.

That is what makes this issue so dangerous. Professional laundering does not always look like crime. It often looks like routine business, properly signed and correctly filed. The challenge for regulators, prosecutors, and supervisory bodies is to see past the paperwork and confront the system that makes such laundering possible.

Dive deeper

• GI-TOC ¦ Licence to launder: Professional enablers and the architecture of illicit finance in the Western Balkans ¦ Link