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.
As a result of Hungary’s progress in strengthening its framework to tackle money laundering and terrorist financing since its mutual evaluation in September 2016, MONEYVAL has re-rated the country on 13 of the 40 Recommendations. Hungary has been in an enhanced follow-up process, following the adoption of its mutual evaluation, which assessed the effectiveness of Hungary’s anti-money laundering and counter-terrorist financing (AML/CFT) measures and their compliance with the Recommendations by the Financial Action Task Force (FATF). In line with the MONEYVAL’s rules of procedure, the country has reported back to MONEYVAL on the progress it has made to strengthen its AML/CFT framework.