METHODOLOGICAL TOOLS FOR ANALYZING THE ACTIVITIES OF PRIMARY FINANCIAL MONITORING ENTITIES

Abstract

The article addresses the pressing need to gauge how Ukraine’s primary financial-monitoring entities (PFMEs) withstand simultaneous shocks from regulatory tightening, the COVID-19 pandemic, and full-scale war, circumstances that have magnified moneylaundering and terrorism-financing risks. The study aims to develop and apply an integrated assessment toolkit that combines a transparent binary scoring grid with a Bayesian probability model to track PFME activity over 2011-2023. The empirical analysis, built on forty-five official indicators, shows a steady rise in compliance until 2019 with a historical peak in 2017-2019, a sharp contraction during 2020-2022, and an incipient rebound in 2023 as institutions adapt to remote supervision and digital workflows. Digital reporting channels prove the most resilient dimension, whereas court-and prosecution-related indicators suffer the deepest wartime setbacks, highlighting capacity gaps beyond the financial sector itself. The integrated methodology captures these nuances more effectively than static checklists and provides regulators with an evidence base for recalibrating risk-based supervision, prioritizing end-to-end digital infrastructure, and reallocating resources toward investigative and judicial bottlenecks. The findings confirm that adaptive, data-driven oversight can bolster the national anti-money-laundering framework even under extreme stress and suggest that the proposed toolkit is transferable to other transition or conflict-affected economies seeking to strengthen financial crime prevention during recovery.