The role of the CNB

Published: 25/5/2015 Modified: 14/2/2020
The CNB as a supervisory body oversees the implementation of national legislation governing the prevention of money laundering and terrorist financing and the implementation of Regulation (EU) 2015/847 and Commission Delegated Regulation (EU) 2018/1108 in credit institutions, credit unions, payment institutions, electronic money institutions, branches of equal reporting entities from other member states and third countries and at representatives for payment institutions or distributors for electronic money institutions from other member states should they be credit institutions, credit unions, institutions for payment services and institutions for electronic money established in the Republic of Croatia in line with the relevant act. It adopts subordinate legislation and guidelines and exercises supervision of these obligated persons. Following supervision, the CNB gives recommendations for the improvement of prevention systems in obligated persons.

To educate obligated persons, it continuously organises training, issues opinions and interpretations of regulations for obligated persons under its supervision and participates in the drafting of regulations in this area.

The CNB enters into agreements or memoranda of understanding, cooperation and exchange of information with domestic and international bodies.

In early 2019, the CNB and the European Central Bank (ECB) concluded a multilateral agreement on the practical modalities for exchange of information pursuant to Article 57a(2) of Directive (EU) 2015/849.

The CNB is active in the training of obligated persons under the CNB's supervision in cooperation with the Croatian Chamber of Economy (CCE) or the Croatian Banking Association (CBA), whether in holding seminars, the work of working groups or interpreting specific questions in this area.

The CNB cooperates with domestic bodies based on the following agreements: Agreement on the Exchange of Information and Cooperation in the Area of Supervision over the Implementation of the Anti Money Laundering and Terrorist Financing Law with the Ministry of Finance of the Republic of Croatia – 2015. Due to a broad range of services which banks may offer to their customers, the CNB also has the Agreement on Cooperation with the Croatian Financial Services Supervisory Agency, which regulates inter-institutional cooperation in supervision over such institutions. The Croatian Financial Services Supervisory Agency (HANFA) and the CNB cooperate and coordinate their activities through the Working Committee for Financial System Supervision. Apart from supervision, cooperation also consists in a continuous exchange of information related to individual matters and the issuing of licences and approvals as well as in initiating and adopting legislation. In case of some open issues, ad hoc working groups, consisting of the representatives of both institutions, can also be set up to jointly seek possible solutions and propose the one that is the most appropriate for a given issue.

The CNB also cooperates with other bodies within the system through the intermediation of the Inter-institutional Working Group for Preventing Money Laundering and Terrorist Financing (IIWG) on the basis of the signed Protocol on Cooperation and Establishment of an Inter-institutional Working Group for Preventing Money Laundering and Terrorist Financing. The IIWG comprises representatives of the Ministry of Justice, the State Attorney's Office, the Ministry of the Interior, the Ministry of Finance (the Customs Administration, the Tax Administration, the Financial Inspectorate and the Anti-Money Laundering Office), the Croatian Financial Services Supervisory Agency, the Security and Intelligence Agency, the Ministry of Foreign and European Affairs and the CNB. The IIWG is responsible for coordinating the measures and reporting on the implementation of the Action Plan for the Prevention of Money Laundering and Terrorist Financing, coordinating the preparation of the reports for MONEYVAL, promoting inter-institutional cooperation in this area and proposing improvements in legislation, implementing regulations, guidelines, etc.

The Croatian National Bank cooperates with institutions abroad on the basis of agreements and memoranda of understanding and cooperation.

In coordination by the Ministry of Foreign and European Affairs, CNB employees take part in the work of the National Commission for the Prevention and Suppression of Terrorism and the Standing Coordinating Group (SCG) for monitoring the implementation of international restriction measures and monitoring and coordination of restriction measures application.

The Commission was established by the Decision of the Government of the Republic of Croatia in July 2014. Commission members are representatives of the following bodies: the Ministry of Foreign and European Affairs, the Ministry of the Interior, the Ministry of Finance, the Ministry of Defence, the Ministry of Justice, the Ministry of the Economy, the Ministry of Maritime Affairs, Transport and Infrastructure, the Office of the President of the Republic of Croatia, the Office of the National Security Council, the Office for Human Rights and Rights of National Minorities, the Security and Intelligence Agency, the Military Security and Intelligence Agency, the State Attorney's Office of the Republic of Croatia, the National Protection and Rescue Directorate and the CNB. The tasks of the Committee include the coordination of activities for the implementation of the National Strategy for the Prevention and Suppression of Terrorism and of the relevant Action Plan, the coordination of activities and guidelines of international counter-terrorism initiatives, monitoring the implementation of the stated measures and preparing reports and opinions of the Republic of Croatia for the purposes of international counter-terrorism cooperation.

The SCG, whose members, among others, also include CNB representatives, was established by the Government of the Republic of Croatia pursuant to Article 5 of the Act on the International Restriction Measures. The terms of reference of the SCG include the implementation of the UN's sanction regime against Al Qaida and the Taliban, established by the United Nations Security Council Resolution 1267 (1999), as well as of the EU's counter-terrorism sanctions regime.