The deficiencies were as follows: no initiatives have been adopted to transpose the risks and the vulnerabilities identified into (coordinated) national AML/CFT policies and strategies; no initiatives have been adopted to transfer the findings of the NRA into the activities of the competent authorities; the coordination and the cooperation among competent authorities for the development and implementation of AML/CFT policies and activities is marginal; and no coordination and cooperation mechanisms are in place for PF.

A coordinated Action Plan for the implementation of the AML recommendations formulated in Hungary’s MER was adopted by Government in Resolution no. 1688/2017 (IX.22). Although the Action Plan will contribute to strengthening national cooperation and coordination, it does not appear to have been designed to mitigate ML/FT risks identified in the NRA. A Government Resolution specifically aimed at mitigating the NRA risks has been agreed upon and is currently under inter-ministerial discussion.

Various actions were undertaken to enhance cooperation and coordination on policy-making and operational levels: the role of the AML Sub-Committee has been reinforced (its mandate covers NRA and PF issues); Government Resolution of 1333/2017. (VI. 9.) establishes an action plan for updating the NRA, including coordinated actions by the relevant institutions; the development and implementation of the Action Plan on MONEYVAL recommendations have contributed to closer cooperation between relevant authorities at policy and operational level; there have been several high-level meetings on the prioritisation of the implementation of MONEYVAL recommendations; and Section 70 of the new AML/CFT Act emphasizes inter-agency coordination for the purposes of supervision.

Progress has also been achieved in reinforcing cooperation and coordination in relation to PF-issues. As noted, the Charter of the AML Sub-Committee now covers PF matters. Experts from the AML Sub-Committee and the informal Inter-ministerial Committee on Non-Proliferation have become permanent delegates in the other institution’s meetings.