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GI-TOC Report / Notaries and "Real Estate" drug money laundering mechanisms under construction in the Western Balkans!

Politiko 2026-06-18 15:59:43

GI-TOC Report / Notaries and "Real Estate" drug money laundering

In the Western Balkans, illicit money rarely moves on its own. It passes through notarized contracts, property deeds, loan agreements, invoices, and audited financial statements, documents that require the signature, certification, or stamp of a licensed professional to appear legitimate.

This report examines the professionals who provide that signature: notaries, lawyers, accountants, auditors and real estate brokers.
Drawing on 89 interviews conducted in Albania, Bosnia and Herzegovina, Kosovo, Montenegro, North Macedonia and Serbia between December 2024 and January 2026, as well as court files, national risk assessments and MONEYVAL reports, the report analyses how these “gatekeepers” can stop illicit financing at the source or, on the contrary, pave the way for it.

Real estate remains the main channel for money laundering. The same patterns are repeated in all six countries: undervalued or overvalued purchase contracts, quick resales between related parties, notarized loans without a reliable source of funds, and nominal buyers acting on behalf of the true beneficial owner.

Shell companies, fictitious invoices and cross-border corporate structures add further layers of concealment. These schemes are usually not managed by a single individual, but are facilitated by the same close circle of notaries, lawyers and accountants who appear in numerous transactions. An Italian accountant, recorded discussing the movement of funds through Albania and Montenegro, described the process in no uncertain terms: “First we will make them disappear, then we will transfer them to Hong Kong or somewhere else.”

Western Balkan countries have largely aligned their anti-money laundering frameworks with the recommendations of the Financial Action Task Force (FATF) and European Union standards. The weakest link remains supervision. Professional associations often lack the authority, resources or staff to effectively monitor their members, while professional secrecy is often interpreted so broadly that transactions that should have raised suspicions go unreported. In Montenegro, for example, notaries processed approximately 19,857 property sales with an estimated value of 1.6 billion euros in 2024, while submitting only two suspicious transaction reports.

The report concludes by identifying the elements of a more effective system: clearer boundaries for professional secrecy, stronger integrity and background checks for notaries and accountants, standardized reporting forms, and functional communication mechanisms between financial intelligence units and professionals reporting suspicious transactions.
The full findings, country analysis, and case studies are presented below/ Globalinitiative.net