Compliance, Effectiveness, and the Cost of Capital: Reading Albania’s MONEYVAL File on European Terms

The on-site mission has concluded. The accession-relevant question is not whether Tirana has demonstrated progress, but what the assessment methodology will actually measure, and what its findings will mean for capital flows, banking-system credibility, and the IBAR track.

by Bekim Besimi (Venice, Italy)

The MONEYVAL assessment mission concluded its on-site work in Tirana on 24 April. The mutual evaluation report it will deliver later in 2026 will be read by two audiences with very different sensitivities: European Commission desk officers preparing the COELA file, and international banking compliance functions that determine correspondent relationships and enhanced due diligence settings. Neither audience works from the question Albania’s domestic political communications appear to be answering. The question that gets asked in Tirana is whether the country has demonstrated progress. The question those external audiences ask is more demanding. They want to know what the methodology measures, whether the institutional architecture supports the measurements, and whether the trajectory is durable enough to revise the cost-of-capital assumptions that follow from AML risk.

On that more precise question, the available evidence is more substantive than the public debate has acknowledged.

The bar has moved since 2018.

Albania’s 2018 mutual evaluation report was its first under the eleven Immediate Outcome framework introduced by the 2013 FATF methodology, which assesses both technical compliance and effectiveness. The effectiveness ratings the 2018 MER produced were generally Low or Moderate across most Immediate Outcomes, with particular deficiencies on IO 7 (investigation and prosecution of money laundering) and IO 8 (confiscation). Those ratings are the baseline.

The 6th round MONEYVAL evaluation now under way operates under the 2022 procedures, which refine the effectiveness assessment with tighter scrutiny of how systems perform in practice rather than how legislation reads. The framework is continuous with 2013, but the bar is higher and the measurement more granular. Effectiveness ratings remain slow to move because they cannot be lifted by legislative drafting alone. They require institutions that function as designed, throughput that can be documented, and outcomes that hold up to peer review.

The October 2023 grey list exit closed Albania’s ICRG action plan, and it did so partly on effectiveness grounds: the FATF plenary explicitly cited a meaningful increase in money laundering indictments, particularly in cases stemming from foreign predicate offences with proceeds laundered domestically. That recognition is the second baseline. What has accumulated since is a wider institutional case that goes beyond what the action plan was designed to test.

The architecture is no longer aspirational.

The Financial Intelligence Agency now operates as the technical secretariat of the Inter-institutional Coordination Committee for AML/CFT, with the 2024 to 2030 National Strategy formally adopted. SPAK is six years past its operational launch in December 2019, with specialised prosecution sections in seven main prosecutor offices and the Special Court functioning as the institutional locus for corruption-linked money laundering. The Beneficial Ownership Register has been operational since the August 2020 law transposing MONEYVAL recommendations on transparency of indirect control. The orderly succession of Klodjan Braho to the SPAK chairmanship in December 2025, on completion of Altin Dumani’s three-year mandate, demonstrated that the institutional design is now operating as an institution rather than as the project of a single appointee. None of this infrastructure existed in 2018.

The legislative pipeline added a further layer in mid-April 2026, when a new draft law on the prevention of money laundering and terrorism financing entered public consultation. The text transposes the European Union’s 6th Anti-Money Laundering Directive (Directive (EU) 2024/1640) and the associated regulatory package on financial-institution supervision. It establishes an obligation regime for crypto-assets requiring verified, immutable identification of sender and beneficiary on every transfer. It lowers the cash declaration threshold at the border to 10,000 euros. It calibrates new luxury-goods reporting thresholds against the asset classes most exposed to regional laundering risk: vehicles above 250,000 euros, vessels and aircraft above 7.5 million euros. It expands the FIA’s powers to include temporary suspension of suspicious transactions, issuance of typology warnings, and enhanced monitoring of obligated entities. It introduces a fourteen-day discrepancy reporting duty against the Beneficial Ownership Register for obligated entities, an obligation that will sharpen the operational value of a register that until now has functioned as a static disclosure tool.

The Directive’s general transposition deadline for EU member states is 10 July 2027. As of April 2026, no member state has completed full transposition because the deadline has not arrived, and intermediate provisions on beneficial ownership register accessibility are themselves still in roll-out across the Union. Albania, which is not yet a member state and is not bound by the Directive, has nonetheless put its transposition draft into public consultation more than a year ahead of the deadline that would apply to it as a member. The pace is voluntary and forward-leaning.

The empirical record matched the architecture in 2025.

Architecture without throughput does not satisfy effectiveness assessment. The 2025 record shows the throughput. State institutions seized or confiscated criminal assets valued at over 65 million euros, the highest annual figure on record, with 726 properties seized and 64 confiscated, the confiscated assets channelled into fifteen social programmes and twenty public institutions through a newly operational asset-management mechanism. SPAK’s own annual report, published in March 2026, recorded total seizures and confiscations of 45.4 million euros directly under its mandate, including for the first time confiscations denominated in cryptocurrency. The cumulative SPAK asset recovery total since 2020 has crossed 330 million euros, a figure the institution has noted is the highest in the Western Balkans by a significant margin.

The volume matters less than the back-end function. Confiscation throughput is the IO 8 effectiveness measure, and under the 2022 procedures it requires both adjudicated outcomes and a functioning post-confiscation framework. Albania now has both.

Bank of Albania supervision tightened in parallel. The 2025 review of foreign exchange bureau licensing strengthened beneficial ownership integrity requirements specifically aligned to MONEYVAL expert recommendations. The BoA’s Director of Supervision reported in February 2026 that all 2018 MONEYVAL technical compliance tasks had been closed.

The prosecutorial record is now in evidence.

Architecture and throughput converge on the IO 7 question. SPAK’s 2025 annual report documents 871 criminal proceedings under investigation, a 4.9 percent increase on 2024. The proactivity indicator that MONEYVAL assessors specifically test, the share of new investigations opened ex officio by prosecutors rather than referred in by other institutions, rose from 19.8 percent in 2024 to 37 percent in 2025. That movement is the most direct available signal that the system is no longer waiting to be triggered.

The case record matches the throughput numbers. Former President Ilir Meta was arrested in October 2024 and formally indicted in May 2025 on charges of money laundering, passive corruption, and concealment of assets. Sitting Tirana Mayor Erion Veliaj was arrested by SPAK in February 2025 on charges including money laundering, with the investigation focused on financial flows through a network of non-governmental organisations. The AKSHI investigation that broke in late 2025 included money laundering among its charge sheet against the agency’s director and connected business operators. Former Deputy Prime Minister Arben Ahmetaj was indicted on money laundering charges connected to the incinerator concessions before fleeing the country. These are not procurement-corruption cases dressed up as money laundering. They are cases in which prosecutors have specifically charged the IO 7 offence and in which the financial trails are central to the prosecution theory.

Beneath the high-profile docket, the structural typology evidence is moving in the same direction. SPAK confiscated more than forty commercial entities used as money-laundering vehicles in 2024, against ten such confiscations in 2010. International cooperation, the IO 2 effectiveness measure, is documented in joint operations with Eurojust and Europol that produced 66 arrests, 360 kilograms of cocaine seized, and 65 million dollars in assets recovered against an Albanian-led organised crime group laundering through 400 million dollars in falsified invoices. A separate joint operation with Kosovo’s Special Prosecution targeting cybercrime-derived laundering produced 1.5 million euros seized in each jurisdiction.

Effectiveness assessors evaluating IO 7 are looking for proactive case origination, financial-trail prosecution methodology, demonstrated typology coverage, and operational international cooperation. All four are now in the file.

What this means for the cost of capital, and for the accession track.

The economic consequence of AML credibility is the part of this story that Tirana commentary tends to skip and Brussels commentary tends to assume. Grey list status carries measurable financial-system costs. Enhanced due diligence requirements on correspondent banking relationships raise transaction costs and lengthen settlement times. Sovereign borrowing margins absorb a portion of the AML risk premium. Foreign direct investment in sectors that require confidence in formal financial channels, banking, financial intermediation, capital-intensive infrastructure, faces compliance friction that real-estate FDI does not.

How much friction, in basis-point terms, the October 2023 grey list exit removed from Albanian sovereign issuance and from correspondent banking pricing is not separately estimated in publicly available analysis. The Bank of Albania has not published a decomposition isolating the AML risk premium, and the country’s Eurobond curve does not have the depth to allow that component to be cleanly extracted from the broader convergence trade. What can be said with confidence is that the directional effect runs through three channels: correspondent banking compliance overhead, sovereign spread composition, and the friction tax on FDI in sectors where formal financial intermediation is unavoidable. The MONEYVAL effectiveness ratings will move each of those channels, marginally for institutional investors who are already inside the file, more visibly for the longer tail of foreign capital that uses headline ratings as a screening shortcut.

This is the analytical bridge between AML reform and the FDI composition problem this publication has examined elsewhere. Productive FDI requires functioning formal financial channels. Confidence in those channels is partly a function of how the international system rates the AML supervisory architecture behind them. Each step of MONEYVAL credibility lowers the implicit compliance tax on the kind of FDI Albania most needs to attract, and that is precisely the FDI category whose under-representation in the 2024 and 2025 figures is the structural problem at the centre of Albania’s productivity gap.

The accession track reads the same evidence through a different lens. Chapter 4 of the EU acquis on free movement of capital and Chapter 24 on justice, freedom and security both carry substantial AML/CFT components. The MONEYVAL effectiveness ratings are not a formal input to the COELA process, but they are read directly by the desk officers preparing the IBAR file and the Commission’s annual country report. A jurisdiction that has put 6th AMLD transposition into consultation more than a year ahead of the member-state deadline, that operates under a published 2024 to 2030 National Strategy, that has documented confiscation throughput at IO 8 levels, and that has demonstrated proactive prosecutorial origination at IO 7 levels, is a jurisdiction whose accession file on these chapters is no longer evidentially deficient.

This does not collapse the political question of Albania’s accession trajectory. It does change what the technical file looks like when it reaches Brussels.

The dataset is not closed. The United States Department of State’s 2025 International Narcotics Control Strategy Report continues to classify Albania as a Major Money Laundering Jurisdiction, a designation Albania has held since 2017. The same report identifies construction-sector laundering as a continuing typology vulnerability and cites the SPAK-Eurojust-Europol joint operation as evidence of operational capability. Both readings are in the same document, and both will be in the MONEYVAL report. Transparency in beneficial ownership data and in publicly accessible enforcement statistics remains uneven. Prosecutorial throughput on financial investigations beyond the high-profile docket has grown but has not yet been demonstrated as systematically distributed across smaller cases. The new draft law has entered consultation but has not been adopted. The MONEYVAL ratings, when they land, will not be uniform across the eleven Immediate Outcomes.

But the position that Albania’s AML system has not changed in any meaningful way is empirically untenable. The 2018 effectiveness baseline, the 2023 grey list exit on partly effectiveness grounds, the 2025 confiscation record, the 6th AMLD transposition pace, and the SPAK proactivity and case-record shift together describe a system that has moved across multiple dimensions in a coordinated direction. European decision-makers reading the file at year end will not be reading the social media posts. They will be reading the architecture, the throughput, and the trajectory. Those three are aligned, and the cost of capital follows the alignment with a lag.

That is what the file says, and it is what the file says in the language the methodology is written to read.

Bekim Besimi writes from Venice, Italy, where he contributes to The Tirana Examiner with a focus on economic governance, public finance, and fiscal transparency in the Western Balkans. His reporting examines how political narratives intersect with budgetary realities and institutional data.