When discussions about money laundering arise, public attention usually turns to criminal groups, corrupt politicians, drug traffickers or organized crime networks. Rarely do we focus on the professionals who sit at the gateway between illicit wealth and the legal economy.
Yet without those gatekeepers, laundering criminal proceeds would be significantly more difficult.
This week, the Global Initiative Against Transnational Organized Crime (GI-TOC) published Licence to Launder: Professional Enablers and the Architecture of Illicit Finance in the Western Balkans – the first regional study dedicated specifically to understanding the role of professional enablers in money laundering across the Western Balkans.
The publication marks an important milestone not only because of its regional scope, but because it addresses a long-overlooked dimension of financial crime. While policymakers and law enforcement agencies have paid considerable attention to criminal networks themselves, much less focus has been directed at the lawyers, notaries, accountants, auditors, company service providers, and real estate intermediaries who may knowingly—or sometimes negligently—facilitate the movement of illicit wealth into legitimate markets.
The report is based on extensive fieldwork, interviews across six Western Balkan jurisdictions, and analysis of anti-money laundering frameworks, enforcement practices and institutional vulnerabilities. Its findings reveal a paradox. On paper, the region has made significant progress in aligning its anti-money laundering systems with European Union and international standards. In practice, implementation gaps continue to create opportunities for abuse.
This conclusion did not emerge in isolation.
For several years, my research has focused on the intersection between organized crime, corruption and financial flows in Southeast Europe. One recurring finding has been that criminal profits rarely remain in the shadows for long. They eventually seek legitimacy. They enter real estate markets, corporate structures, public procurement systems and investment schemes. To do so, they often require assistance from actors operating within the legal economy.
This was a central theme in earlier research, including Washing Away Crime, which examined how criminal proceeds are integrated into legitimate economic sectors and why anti-money laundering systems frequently fail to detect them. That work highlighted how vulnerabilities in oversight, beneficial ownership transparency and professional accountability enable illicit finance to flourish despite increasingly sophisticated regulatory frameworks.
The new report expands that analysis by focusing specifically on the professional ecosystem surrounding illicit finance. What emerges is not a story of widespread professional complicity, but rather one of systemic vulnerabilities. Most lawyers, accountants, notaries and auditors perform their duties ethically and professionally. However, when oversight is fragmented, reporting obligations are weakly enforced, and professional secrecy is interpreted too broadly, even a small number of bad actors can create disproportionate risks.
The findings are particularly relevant as Western Balkan countries continue their European integration journeys. The European Union has repeatedly emphasized the importance of strengthening the rule of law, combating corruption, and improving the fight against money laundering. Yet these objectives cannot be achieved solely through stronger policing or harsher penalties. They also require addressing the professional infrastructure that allows illicit funds to acquire a cloak of legitimacy.
The challenge is not unique to the Western Balkans. Recent scandals across Europe, from offshore secrecy arrangements to large-scale sanctions evasion schemes, have demonstrated that professional enablers play a critical role in facilitating illicit finance globally. The difference is that in regions where institutions remain under pressure and oversight capacities are uneven, the risks become even more pronounced.
The policy implications are clear. Governments should strengthen risk-based supervision of designated non-financial businesses and professions, improve access to beneficial ownership information, enhance cooperation between regulators and financial intelligence units, and invest in specialized training. Equally important is fostering a professional culture that recognizes safeguarding the public interest as a core responsibility rather than merely a compliance requirement. However, prevention must be matched by enforcement. More financial investigations, greater use of asset tracing, and a stronger record of prosecutions and convictions for money laundering and related offenses are essential if the region is to move beyond formal compliance and demonstrate tangible results in combating illicit finance.
Ultimately, the fight against money laundering is not only about following the money. It is about understanding who helps move it, conceal it, and legitimize it.
The Western Balkans has spent years strengthening its legal frameworks. The next step is to ensure that the professionals entrusted with protecting the integrity of those systems are equipped, incentivized, and required to do so.
Because dirty money rarely cleans itself.
