The document is a mutual evaluation report on Greece's anti-money laundering and counter-terrorist financing measures. It finds that Greek authorities generally understand money laundering and terrorist financing risks. International cooperation delivers appropriate information to combat criminals. However, supervision of financial institutions and regulation of certain sectors needs improvement. Terrorist financing offenses are investigated substantially but some terrorist financing risks are only moderated.
The document is a mutual evaluation report from July 2019 that assesses Malta's anti-money laundering and counter-terrorist financing framework. It finds Malta's effectiveness in achieving certain AML/CFT objectives is moderate to low. On technical compliance, Malta received largely compliant and partially compliant ratings across preventive measures, legal persons/arrangements, regulation/supervision, and international cooperation. Areas of low or moderate effectiveness include supervising financial institutions/DNFBPs, investigating ML/TF offenses, and confiscating proceeds of crime.
This document is a mutual evaluation report from the Financial Action Task Force (FATF) that assesses the anti-money laundering and counter-terrorist financing measures in place in the Cayman Islands. It provides ratings on the Cayman Islands' level of effectiveness and technical compliance with FATF recommendations. Overall, the Cayman Islands was found to have low effectiveness in 7 of its 11 core areas and was only partially compliant or lower on 18 of its 40 technical compliance recommendations.
The document is a mutual evaluation report on anti-money laundering and counter-terrorist financing measures in Finland from April 2019. It provides ratings on Finland's effectiveness and technical compliance in various areas. It finds that Finland has an adequate understanding of money laundering risks but supervision needs to be more risk-based. International cooperation is effective but more can be done to establish beneficial ownership and improve use of financial intelligence and sanctions. Key priority actions identified are improving risk-based supervision, establishing a beneficial ownership registry, addressing gaps in risk understanding, and encouraging tougher sentencing for money laundering.
This document is a mutual evaluation report on the anti-money laundering and counter-terrorist financing measures in the United Kingdom from December 2018. It provides ratings on the UK's effectiveness and technical compliance in 11 immediate outcomes and 40 FATF recommendations. Overall, the UK demonstrates a robust understanding of its ML/TF risks and proactively investigates terrorism financing. However, opportunities for improvement include increasing resources for financial intelligence analysis, reforming the suspicious activity report regime, and strengthening supervision in some sectors. The report prioritizes actions such as improving public registers of company ownership and ensuring effective risk-based supervision across all entities.
The document is a mutual evaluation report from February 2019 that assesses the anti-money laundering and counter-terrorist financing measures in the Czech Republic. It provides ratings on the country's effectiveness and technical compliance with various FATF recommendations. On effectiveness, most of the ratings are moderate, with a few substantial and high ratings. On technical compliance, most ratings are largely compliant, with some partially compliant ratings. The report contains detailed analysis and ratings across 40 technical compliance criteria.
The document is a mutual evaluation report on Turkey's anti-money laundering and counter-terrorist financing measures. It finds that Turkey has a substantial understanding of ML/TF risks domestically but a moderate level of effectiveness in implementing preventative measures and investigating financial crimes. It identifies priority actions for Turkey to strengthen its AML/CFT system such as prioritizing the use of financial intelligence for ML investigations, developing national strategies for investigating ML offenses and confiscating criminal proceeds, and improving implementation of targeted financial sanctions.
The document is a mutual evaluation report by MONEYVAL that assesses Lithuania's anti-money laundering and counter-terrorist financing measures. It finds Lithuania to be moderately effective in 11 of 12 areas but partially compliant or largely compliant in its technical compliance. Key results include moderate effectiveness in understanding risks, supervising financial institutions and investigating money laundering, with substantial international cooperation.
The document is a mutual evaluation report on anti-money laundering and counter-terrorist financing measures in Cabo Verde. It finds that Cabo Verde has achieved low effectiveness in 11 immediate outcomes related to combating money laundering and terrorist financing. It also rates Cabo Verde as partially compliant or largely compliant on most technical compliance requirements, with low ratings across investigative and prosecutorial frameworks and preventive measures. The report provides ratings and key findings on Cabo Verde's anti-money laundering and counter-terrorist financing regime.
The document is a mutual evaluation report from July 2019 that assesses Malta's anti-money laundering and counter-terrorist financing framework. It finds Malta's effectiveness in achieving certain AML/CFT objectives is moderate to low. On technical compliance, Malta received largely compliant and partially compliant ratings across preventive measures, legal persons/arrangements, regulation/supervision, and international cooperation. Areas of low or moderate effectiveness include supervising financial institutions/DNFBPs, investigating ML/TF offenses, and confiscating proceeds of crime.
This document is a mutual evaluation report from the Financial Action Task Force (FATF) that assesses the anti-money laundering and counter-terrorist financing measures in place in the Cayman Islands. It provides ratings on the Cayman Islands' level of effectiveness and technical compliance with FATF recommendations. Overall, the Cayman Islands was found to have low effectiveness in 7 of its 11 core areas and was only partially compliant or lower on 18 of its 40 technical compliance recommendations.
The document is a mutual evaluation report on anti-money laundering and counter-terrorist financing measures in Finland from April 2019. It provides ratings on Finland's effectiveness and technical compliance in various areas. It finds that Finland has an adequate understanding of money laundering risks but supervision needs to be more risk-based. International cooperation is effective but more can be done to establish beneficial ownership and improve use of financial intelligence and sanctions. Key priority actions identified are improving risk-based supervision, establishing a beneficial ownership registry, addressing gaps in risk understanding, and encouraging tougher sentencing for money laundering.
This document is a mutual evaluation report on the anti-money laundering and counter-terrorist financing measures in the United Kingdom from December 2018. It provides ratings on the UK's effectiveness and technical compliance in 11 immediate outcomes and 40 FATF recommendations. Overall, the UK demonstrates a robust understanding of its ML/TF risks and proactively investigates terrorism financing. However, opportunities for improvement include increasing resources for financial intelligence analysis, reforming the suspicious activity report regime, and strengthening supervision in some sectors. The report prioritizes actions such as improving public registers of company ownership and ensuring effective risk-based supervision across all entities.
The document is a mutual evaluation report from February 2019 that assesses the anti-money laundering and counter-terrorist financing measures in the Czech Republic. It provides ratings on the country's effectiveness and technical compliance with various FATF recommendations. On effectiveness, most of the ratings are moderate, with a few substantial and high ratings. On technical compliance, most ratings are largely compliant, with some partially compliant ratings. The report contains detailed analysis and ratings across 40 technical compliance criteria.
The document is a mutual evaluation report on Turkey's anti-money laundering and counter-terrorist financing measures. It finds that Turkey has a substantial understanding of ML/TF risks domestically but a moderate level of effectiveness in implementing preventative measures and investigating financial crimes. It identifies priority actions for Turkey to strengthen its AML/CFT system such as prioritizing the use of financial intelligence for ML investigations, developing national strategies for investigating ML offenses and confiscating criminal proceeds, and improving implementation of targeted financial sanctions.
The document is a mutual evaluation report by MONEYVAL that assesses Lithuania's anti-money laundering and counter-terrorist financing measures. It finds Lithuania to be moderately effective in 11 of 12 areas but partially compliant or largely compliant in its technical compliance. Key results include moderate effectiveness in understanding risks, supervising financial institutions and investigating money laundering, with substantial international cooperation.
The document is a mutual evaluation report on anti-money laundering and counter-terrorist financing measures in Cabo Verde. It finds that Cabo Verde has achieved low effectiveness in 11 immediate outcomes related to combating money laundering and terrorist financing. It also rates Cabo Verde as partially compliant or largely compliant on most technical compliance requirements, with low ratings across investigative and prosecutorial frameworks and preventive measures. The report provides ratings and key findings on Cabo Verde's anti-money laundering and counter-terrorist financing regime.
The document is a mutual evaluation report on Denmark's anti-money laundering and counter-terrorist financing framework. It finds that Denmark has a moderate understanding of money laundering risks but better understands terrorist financing risks. It also finds weaknesses in Denmark's risk assessments, national coordination, supervision of financial institutions for compliance, application of preventive measures by financial institutions, and legal framework for targeted financial sanctions. The report lists priority actions for Denmark to strengthen its framework, such as improving national risk assessments, developing policies based on risks, increasing resources for competent authorities, and enhancing supervision and sanctions.
The document is a mutual evaluation report on Colombia's anti-money laundering and counter-terrorist financing measures. It provides ratings on Colombia's level of effectiveness and technical compliance in 40 areas. For effectiveness, Colombia received substantial ratings for understanding ML/TF risks and international cooperation, but low ratings for investigating money laundering, terrorist financing, and proliferation financing offenses. For technical compliance, Colombia received largely compliant or compliant ratings for most preventive measures and powers of competent authorities, but partially compliant for others like targeted financial sanctions and transparency of legal persons.
The document is a mutual evaluation report on anti-money laundering and counter-terrorist financing measures in Peru. It provides ratings on Peru's level of effectiveness and technical compliance in various areas. On effectiveness, Peru was rated as moderate or substantial in most areas, except for legal persons/arrangements and ML prosecution which were rated low. On technical compliance, Peru was rated as compliant or largely compliant in most areas, except for non-profit organizations, reliance on third parties, and transparency of legal persons/arrangements which were rated partially compliant.
This document is a mutual evaluation report on Ireland's anti-money laundering and counter-terrorist financing framework. It finds that Ireland has a generally sound AML/CFT framework and has improved its understanding of risks through coordination mechanisms. However, further measures are needed to fully identify international money laundering risks and ensure a fully effective system commensurate with risks. While national coordination is a strength, supervisors of some high-risk sectors are under-resourced. The private sector's understanding of risks is mixed, but expected to improve over time through continued authorities' outreach.
CFATF Mutual Evaluation Report of Barbados - 2018Clare O'Hare
The document is a mutual evaluation report on Barbados' anti-money laundering and counter-terrorism financing measures. It finds that while Barbados has made some progress, it has only a low level of effectiveness in implementing its AML/CFT regime. In particular, its national risk assessment failed to fully identify ML/TF risks. Beneficial ownership information for legal persons and arrangements is collected but authorities have not verified that it is accurately maintained and available. Overall, the report provides ratings and findings on the technical compliance and effectiveness of Barbados' AML/CFT systems.
This document is a mutual evaluation report from September 2018 that assesses the anti-money laundering and counter-terrorist financing measures in place in the Cook Islands. It provides ratings on the Cook Islands' level of effectiveness and technical compliance in 11 areas related to combating money laundering and terrorist financing. The ratings indicate the Cook Islands has achieved substantial or moderate effectiveness in most areas but is low or moderate in investigating money laundering offenses, confiscating proceeds of crime, and applying sanctions.
The document is a mutual evaluation report by MONEYVAL on Ukraine's anti-money laundering and counter-terrorist financing measures. It finds that Ukraine has a reasonably good understanding of its money laundering and terrorist financing risks, though understanding of some risks could be improved. Corruption poses a significant overarching money laundering risk. Ukraine has national coordination mechanisms to address identified risks, but needs further efforts to mitigate risks from fictitious entrepreneurship, the shadow economy, and cash use. The Financial Intelligence Unit generates high quality financial intelligence that supports money laundering and terrorist financing investigations.
This document is a mutual evaluation report on the anti-money laundering and counter-terrorist financing measures in the Dominican Republic. It provides ratings on the Dominican Republic's level of effectiveness and technical compliance in implementing AML/CFT measures. For effectiveness, the Dominican Republic was rated as moderate or substantial for most immediate outcomes, with a few ratings of low. For technical compliance, it received mostly largely compliant or compliant ratings for most recommendations, with a few partially compliant ratings.
The document is a mutual evaluation report by MONEYVAL on Latvia's anti-money laundering and counter-terrorist financing measures. It finds that while Latvia has produced national risk assessments of money laundering and terrorist financing, there is uneven understanding of cross-border financial risks. Competent authorities have access to financial intelligence but reporting of suspicious transactions needs improvement. The report provides ratings on Latvia's technical compliance and effectiveness in combating money laundering, terrorist financing, and proliferation financing. It identifies several areas where Latvia is partially compliant or needs to improve.
This document is a mutual evaluation report on anti-money laundering and counter-terrorist financing measures in Tajikistan. It provides ratings on Tajikistan's level of effectiveness and technical compliance with FATF recommendations. Overall, Tajikistan was found to have a substantial system for combating money laundering and terrorist financing risks, though more progress is needed, particularly in prosecuting money laundering, applying targeted financial sanctions, and regulating designated non-financial businesses and professions. The report includes detailed ratings across 11 immediate outcomes and 40 technical compliance components.
This document contains a mutual evaluation report on anti-money laundering and counter-terrorist financing measures in the Russian Federation. It finds that Russia has a substantial system to understand risks and coordinate actions domestically and internationally. However, it also finds room for improvement in supervision of financial institutions, investigation of complex money laundering, and fully implementing targeted financial sanctions without delay. Priority actions recommended include strengthening risk-based supervision, prioritizing complex money laundering cases, and requiring all persons and entities to implement terrorist financing sanctions without delay.
The document is a mutual evaluation report on anti-money laundering and counter-terrorist financing measures in Macao, China. It provides ratings on Macao's effectiveness and technical compliance in these areas. On effectiveness, Macao received moderate or substantial ratings for most outcomes, except for low ratings on money laundering investigations/prosecutions and proceeds/instrumentalities of crime confiscation. On technical compliance, Macao was largely or fully compliant in most areas, except for being partially compliant on DNFBP preventive measures and non-compliant on cash couriers. Key findings note coordination mechanisms for AML/CFT but a mixed understanding of risks, as well as intelligence sharing and use, but gaps in
Assessment of the measures to combat money laundering and the financing of terrorism and proliferation in the Kingdom of Bahrain: ratings, key findings and priority actions.
This document is a mutual evaluation report on Israel's anti-money laundering and counter-terrorist financing measures. It finds that Israel has a good understanding of its money laundering and terrorist financing risks. Key findings include that Israel has strong domestic coordination of AML/CFT policies and that authorities are successfully prosecuting money laundering and confiscating criminal proceeds. However, it also identifies some priority actions, such as fully implementing preventative measures for all designated non-financial businesses and professions, and enhancing regulation and supervision for some high-risk sectors.
This document is a mutual evaluation report on anti-money laundering and counter-terrorist financing measures in Saudi Arabia published in September 2018. It provides ratings and key findings on Saudi Arabia's level of effectiveness and technical compliance. On effectiveness, Saudi Arabia demonstrated substantial understanding of risks but was rated low or moderate on most outcomes. Key findings include weaknesses in complex money laundering investigations and pursuing criminal proceeds. On technical compliance, Saudi Arabia was largely or fully compliant on most recommendations. Priority actions focus on improving money laundering investigations, pursuing international cooperation, and strengthening targeted financial sanctions implementation.
The document is a mutual evaluation report on anti-money laundering and counter-terrorist financing measures in Burkina Faso from May 2019. It finds that Burkina Faso has achieved low effectiveness in 11 of 11 immediate outcomes to combat money laundering and terrorist financing. On technical compliance, it rates Burkina Faso as compliant on 9 recommendations, largely compliant on 17, partially compliant on 13, and non-compliant on 1 recommendation.
The document is a mutual evaluation report by MONEYVAL that assesses Moldova's anti-money laundering and counter-terrorist financing measures. It finds that Moldova achieved substantial or moderate effectiveness for most outcomes, except low effectiveness for preventing proliferation financing. Technically, it was largely or partially compliant for most recommendations, except fully compliant for 4-5 recommendations. The report provides ratings on Moldova's effectiveness and technical compliance with Financial Action Task Force standards.
The document is a mutual evaluation report from September 2018 that assesses Seychelles' anti-money laundering and counter-terrorist financing measures. It finds that Seychelles has a low level of effectiveness in 11 of its core objectives. On a technical level, it finds Seychelles to be partially compliant or non-compliant in over half of the 40 Financial Action Task Force recommendations. Overall, the report gives Seychelles poor ratings for both the effectiveness and technical implementation of its anti-money laundering and counter-terrorism financing systems.
This document contains a mutual evaluation report of Zambia's anti-money laundering and counter-terrorist financing measures. It finds that Zambia has a moderate level of effectiveness in 11 of 12 immediate outcomes but is low for preventing legal persons and arrangements from being misused. Technically, Zambia is partially compliant or largely compliant for most recommendations, except for targeted financial sanctions related to proliferation where it is non-compliant. The report provides ratings for both effectiveness and technical compliance of Zambia's anti-money laundering systems.
This document contains a mutual evaluation report on anti-money laundering and counter-terrorist financing measures in Hong Kong, China from September 2019. It provides ratings on Hong Kong's effectiveness and technical compliance in 11 immediate outcomes and 40 recommendations. Overall, Hong Kong demonstrates a substantial level of effectiveness in 7 of the 11 outcomes, but a moderate level in 4 outcomes related to supervision and application of preventative measures. The report also finds that Hong Kong has a reasonably good but incomplete understanding of money laundering risks and recommends it deepen its understanding in some higher risk areas.
The document is a mutual evaluation report on Denmark's anti-money laundering and counter-terrorist financing framework. It finds that Denmark has a moderate understanding of money laundering risks but better understands terrorist financing risks. It also finds weaknesses in Denmark's risk assessments, national coordination, supervision of financial institutions for compliance, application of preventive measures by financial institutions, and legal framework for targeted financial sanctions. The report lists priority actions for Denmark to strengthen its framework, such as improving national risk assessments, developing policies based on risks, increasing resources for competent authorities, and enhancing supervision and sanctions.
The document is a mutual evaluation report on Colombia's anti-money laundering and counter-terrorist financing measures. It provides ratings on Colombia's level of effectiveness and technical compliance in 40 areas. For effectiveness, Colombia received substantial ratings for understanding ML/TF risks and international cooperation, but low ratings for investigating money laundering, terrorist financing, and proliferation financing offenses. For technical compliance, Colombia received largely compliant or compliant ratings for most preventive measures and powers of competent authorities, but partially compliant for others like targeted financial sanctions and transparency of legal persons.
The document is a mutual evaluation report on anti-money laundering and counter-terrorist financing measures in Peru. It provides ratings on Peru's level of effectiveness and technical compliance in various areas. On effectiveness, Peru was rated as moderate or substantial in most areas, except for legal persons/arrangements and ML prosecution which were rated low. On technical compliance, Peru was rated as compliant or largely compliant in most areas, except for non-profit organizations, reliance on third parties, and transparency of legal persons/arrangements which were rated partially compliant.
This document is a mutual evaluation report on Ireland's anti-money laundering and counter-terrorist financing framework. It finds that Ireland has a generally sound AML/CFT framework and has improved its understanding of risks through coordination mechanisms. However, further measures are needed to fully identify international money laundering risks and ensure a fully effective system commensurate with risks. While national coordination is a strength, supervisors of some high-risk sectors are under-resourced. The private sector's understanding of risks is mixed, but expected to improve over time through continued authorities' outreach.
CFATF Mutual Evaluation Report of Barbados - 2018Clare O'Hare
The document is a mutual evaluation report on Barbados' anti-money laundering and counter-terrorism financing measures. It finds that while Barbados has made some progress, it has only a low level of effectiveness in implementing its AML/CFT regime. In particular, its national risk assessment failed to fully identify ML/TF risks. Beneficial ownership information for legal persons and arrangements is collected but authorities have not verified that it is accurately maintained and available. Overall, the report provides ratings and findings on the technical compliance and effectiveness of Barbados' AML/CFT systems.
This document is a mutual evaluation report from September 2018 that assesses the anti-money laundering and counter-terrorist financing measures in place in the Cook Islands. It provides ratings on the Cook Islands' level of effectiveness and technical compliance in 11 areas related to combating money laundering and terrorist financing. The ratings indicate the Cook Islands has achieved substantial or moderate effectiveness in most areas but is low or moderate in investigating money laundering offenses, confiscating proceeds of crime, and applying sanctions.
The document is a mutual evaluation report by MONEYVAL on Ukraine's anti-money laundering and counter-terrorist financing measures. It finds that Ukraine has a reasonably good understanding of its money laundering and terrorist financing risks, though understanding of some risks could be improved. Corruption poses a significant overarching money laundering risk. Ukraine has national coordination mechanisms to address identified risks, but needs further efforts to mitigate risks from fictitious entrepreneurship, the shadow economy, and cash use. The Financial Intelligence Unit generates high quality financial intelligence that supports money laundering and terrorist financing investigations.
This document is a mutual evaluation report on the anti-money laundering and counter-terrorist financing measures in the Dominican Republic. It provides ratings on the Dominican Republic's level of effectiveness and technical compliance in implementing AML/CFT measures. For effectiveness, the Dominican Republic was rated as moderate or substantial for most immediate outcomes, with a few ratings of low. For technical compliance, it received mostly largely compliant or compliant ratings for most recommendations, with a few partially compliant ratings.
The document is a mutual evaluation report by MONEYVAL on Latvia's anti-money laundering and counter-terrorist financing measures. It finds that while Latvia has produced national risk assessments of money laundering and terrorist financing, there is uneven understanding of cross-border financial risks. Competent authorities have access to financial intelligence but reporting of suspicious transactions needs improvement. The report provides ratings on Latvia's technical compliance and effectiveness in combating money laundering, terrorist financing, and proliferation financing. It identifies several areas where Latvia is partially compliant or needs to improve.
This document is a mutual evaluation report on anti-money laundering and counter-terrorist financing measures in Tajikistan. It provides ratings on Tajikistan's level of effectiveness and technical compliance with FATF recommendations. Overall, Tajikistan was found to have a substantial system for combating money laundering and terrorist financing risks, though more progress is needed, particularly in prosecuting money laundering, applying targeted financial sanctions, and regulating designated non-financial businesses and professions. The report includes detailed ratings across 11 immediate outcomes and 40 technical compliance components.
This document contains a mutual evaluation report on anti-money laundering and counter-terrorist financing measures in the Russian Federation. It finds that Russia has a substantial system to understand risks and coordinate actions domestically and internationally. However, it also finds room for improvement in supervision of financial institutions, investigation of complex money laundering, and fully implementing targeted financial sanctions without delay. Priority actions recommended include strengthening risk-based supervision, prioritizing complex money laundering cases, and requiring all persons and entities to implement terrorist financing sanctions without delay.
The document is a mutual evaluation report on anti-money laundering and counter-terrorist financing measures in Macao, China. It provides ratings on Macao's effectiveness and technical compliance in these areas. On effectiveness, Macao received moderate or substantial ratings for most outcomes, except for low ratings on money laundering investigations/prosecutions and proceeds/instrumentalities of crime confiscation. On technical compliance, Macao was largely or fully compliant in most areas, except for being partially compliant on DNFBP preventive measures and non-compliant on cash couriers. Key findings note coordination mechanisms for AML/CFT but a mixed understanding of risks, as well as intelligence sharing and use, but gaps in
Assessment of the measures to combat money laundering and the financing of terrorism and proliferation in the Kingdom of Bahrain: ratings, key findings and priority actions.
This document is a mutual evaluation report on Israel's anti-money laundering and counter-terrorist financing measures. It finds that Israel has a good understanding of its money laundering and terrorist financing risks. Key findings include that Israel has strong domestic coordination of AML/CFT policies and that authorities are successfully prosecuting money laundering and confiscating criminal proceeds. However, it also identifies some priority actions, such as fully implementing preventative measures for all designated non-financial businesses and professions, and enhancing regulation and supervision for some high-risk sectors.
This document is a mutual evaluation report on anti-money laundering and counter-terrorist financing measures in Saudi Arabia published in September 2018. It provides ratings and key findings on Saudi Arabia's level of effectiveness and technical compliance. On effectiveness, Saudi Arabia demonstrated substantial understanding of risks but was rated low or moderate on most outcomes. Key findings include weaknesses in complex money laundering investigations and pursuing criminal proceeds. On technical compliance, Saudi Arabia was largely or fully compliant on most recommendations. Priority actions focus on improving money laundering investigations, pursuing international cooperation, and strengthening targeted financial sanctions implementation.
The document is a mutual evaluation report on anti-money laundering and counter-terrorist financing measures in Burkina Faso from May 2019. It finds that Burkina Faso has achieved low effectiveness in 11 of 11 immediate outcomes to combat money laundering and terrorist financing. On technical compliance, it rates Burkina Faso as compliant on 9 recommendations, largely compliant on 17, partially compliant on 13, and non-compliant on 1 recommendation.
The document is a mutual evaluation report by MONEYVAL that assesses Moldova's anti-money laundering and counter-terrorist financing measures. It finds that Moldova achieved substantial or moderate effectiveness for most outcomes, except low effectiveness for preventing proliferation financing. Technically, it was largely or partially compliant for most recommendations, except fully compliant for 4-5 recommendations. The report provides ratings on Moldova's effectiveness and technical compliance with Financial Action Task Force standards.
The document is a mutual evaluation report from September 2018 that assesses Seychelles' anti-money laundering and counter-terrorist financing measures. It finds that Seychelles has a low level of effectiveness in 11 of its core objectives. On a technical level, it finds Seychelles to be partially compliant or non-compliant in over half of the 40 Financial Action Task Force recommendations. Overall, the report gives Seychelles poor ratings for both the effectiveness and technical implementation of its anti-money laundering and counter-terrorism financing systems.
This document contains a mutual evaluation report of Zambia's anti-money laundering and counter-terrorist financing measures. It finds that Zambia has a moderate level of effectiveness in 11 of 12 immediate outcomes but is low for preventing legal persons and arrangements from being misused. Technically, Zambia is partially compliant or largely compliant for most recommendations, except for targeted financial sanctions related to proliferation where it is non-compliant. The report provides ratings for both effectiveness and technical compliance of Zambia's anti-money laundering systems.
This document contains a mutual evaluation report on anti-money laundering and counter-terrorist financing measures in Hong Kong, China from September 2019. It provides ratings on Hong Kong's effectiveness and technical compliance in 11 immediate outcomes and 40 recommendations. Overall, Hong Kong demonstrates a substantial level of effectiveness in 7 of the 11 outcomes, but a moderate level in 4 outcomes related to supervision and application of preventative measures. The report also finds that Hong Kong has a reasonably good but incomplete understanding of money laundering risks and recommends it deepen its understanding in some higher risk areas.
This document is a mutual evaluation report on anti-money laundering and counter-terrorist financing measures in Kyrgyzstan from September 2018. It finds that while Kyrgyzstan has made efforts to assess risks, it has a limited understanding of money laundering and terrorist financing risks. It has not yet developed a national strategy or action plan to address the risks identified. Financial intelligence is used for investigations but the quality of some underlying data is limited. Law enforcement authorities are aware of their powers but do not take a comprehensive risk-based approach to preventing, identifying and investigating these offenses.
The document is a mutual evaluation report by FATF assessing China's anti-money laundering and counter-terrorist financing framework. It finds China has a well-established framework for domestic cooperation but its FIU arrangement results in incomplete access to information. While China effectively investigates money laundering and prosecutes offenders, it needs to broaden its approach beyond just pursuing predicate crimes. Key recommended actions include strengthening understanding of risks, improving the FIU framework, enhancing targeted financial sanctions, regulating DNFBPs, and improving timely access to beneficial ownership information.
The report evaluates Mauritius' anti-money laundering and counter-terrorist financing (AML/CFT) regime and finds several weaknesses. Mauritius has not fully understood its money laundering and terrorist financing risks. Financial institutions show varying understanding of risks depending on their size, while designated non-financial businesses show little understanding. The regime has not assessed risks in the non-profit sector. Financial institutions in the global business sector are legally obligated to comply with AML/CFT laws but rely heavily on management companies, concentrating risks. Supervisors have not adopted robust risk assessment systems for effective risk-based supervision.
This document contains a mutual evaluation report on anti-money laundering and counter-terrorist financing measures in Senegal from May 2018. It finds that Senegal has achieved low effectiveness in 11 of its core objectives to combat money laundering and terrorist financing. On technical compliance, it rates Senegal as partially compliant or non-compliant on 25 of the 40 FATF recommendations. Overall, the report identifies several priority areas for Senegal to strengthen its anti-money laundering and counter-terrorist financing regime.
This document contains a summary of ratings from a mutual evaluation report on anti-money laundering and counter-terrorist financing measures in Morocco. It finds that Morocco has a moderate level of effectiveness in 11 of 12 identified outcomes, but is low or non-compliant in preventing misuse of legal persons and arrangements. The technical compliance ratings identify areas where Morocco is partially compliant or non-compliant with FATF recommendations, including targeted financial sanctions, regulation of non-profits, and transparency of legal arrangements.
This document is a mutual evaluation report on France's anti-money laundering and counter-terrorist financing system from May 2022. It finds that France has a good understanding of money laundering and terrorist financing risks. Key competent authorities like TRACFIN regularly use financial intelligence and cooperate internationally. However, the report identifies some areas for improvement, including strengthening supervision of certain designated non-financial businesses and professions, increasing awareness of obligations among these sectors, and providing more specialized investigators to combat money laundering. It prioritizes actions like improving supervision of high-risk sectors, increasing resources for money laundering investigations, and enhancing the verification of beneficial ownership information.
The document is a mutual evaluation report on South Africa's anti-money laundering and counter-terrorist financing system. It finds that while South Africa understands some domestic money laundering risks, it has a limited understanding of relative scales, vulnerabilities, and threats from foreign predicates. Understanding of terrorist financing risks is also underdeveloped. It identifies several priority actions for South Africa to strengthen its framework, including developing policies to address higher risk areas, improving international cooperation, and enhancing supervision of at-risk sectors.
The document is a mutual evaluation report on anti-money laundering and counter-terrorist financing measures in the Netherlands. It provides key findings, ratings on effectiveness and technical compliance. Overall, the Netherlands demonstrates a good understanding of risks and has a robust system for domestic cooperation. However, some sectors show limited understanding of risks and obligations. Sanctions for money laundering are generally low. Implementation of targeted financial sanctions requires improved supervision of certain entities.
This document is a mutual evaluation report on Indonesia's anti-money laundering and counter-terrorist financing measures from September 2018. It provides ratings on Indonesia's level of effectiveness and technical compliance in 12 areas. On effectiveness, Indonesia was rated as substantial in 6 areas, moderate in 5 areas, and low in 1 area. On technical compliance, Indonesia was rated as largely compliant in 27 areas, partially compliant in 3 areas, and non-compliant in 1 area.
This document is a mutual evaluation report on Antigua and Barbuda's anti-money laundering and counter-terrorist financing measures. It provides ratings on the country's level of effectiveness and technical compliance in various areas. For effectiveness, Antigua and Barbuda received moderate ratings for most outcomes but low ratings for investigating money laundering offenses and preventing terrorist financing. For technical compliance, it received largely compliant or compliant ratings for most recommendations but partially compliant or non-compliant for others like targeted sanctions and non-profit oversight.
The document is a mutual evaluation report on Cambodia's anti-money laundering and counter-terrorist financing measures. It finds that Cambodia has improved its technical compliance with international standards since 2007, but its regime is not fully effective given ML threats. Cambodia completed its first national risk assessment in 2016, giving it an understanding of ML/TF risks like fraud and corruption, but the assessment had gaps and risks from certain sectors were assessed differently. Cooperation and application of a risk-based approach need to be strengthened for Cambodia to have an effective AML/CFT system.
The document is a mutual evaluation report on Palau's anti-money laundering and counter-terrorist financing measures. It finds that Palau has a moderate level of effectiveness in combating money laundering and terrorist financing. Key findings include that Palau has taken reasonable steps to identify money laundering risks but understanding of risks is limited in the private sector, and that coordination occurs between authorities but additional coordination is needed regarding terrorist financing. It provides ratings for Palau's technical compliance and effectiveness in various areas.
This document is a mutual evaluation report from March 2020 that assesses Korea's anti-money laundering and counter-terrorist financing system. It finds that Korea has a good understanding of its money laundering and terrorist financing risks. However, it identifies several priority areas for Korea to strengthen its framework, including extending anti-money laundering obligations to all designated non-financial businesses and professions, expanding the scope of tax crimes that are money laundering predicates, and addressing technical deficiencies in its implementation of targeted financial sanctions.
This document is a mutual evaluation report on Portugal's anti-money laundering and counter-terrorist financing system from December 2017. It provides ratings on Portugal's level of effectiveness and technical compliance, key findings, and priority actions. Some of Portugal's strengths identified include understanding of ML/TF risks, international cooperation, and prosecuting money laundering cases. Areas for improvement include assessing risks associated with non-profit organizations and legal entities, resourcing the FIU to analyze suspicious transactions, and supervising higher-risk DNFBP sectors.
This document is a mutual evaluation report on anti-money laundering and counter-terrorist financing measures in Japan from August 2021. It provides key findings, ratings on effectiveness and technical compliance. Some of the key findings are that Japan has a good understanding of money laundering and terrorism financing risks but assessments could be improved, financial institutions' understanding of risks varies, and designated non-financial businesses and professions have a low understanding of risks and obligations. Supervisors' understanding of risk is also uneven.
This document is a mutual evaluation report by MONEYVAL that assesses Albania's anti-money laundering and counter-terrorist financing measures. It finds that Albania has achieved moderate to substantial effectiveness in 11 of its core objectives, with lower effectiveness for terrorist financing investigations and proliferation financing prevention. Technically, Albania was found to be compliant or largely compliant for most recommendations, but partially compliant for others related to transparency of legal persons and arrangements, regulation/supervision, and sanctions.
The document is a mutual evaluation report on Singapore's anti-money laundering and counter-terrorist financing measures. It finds that Singapore has a highly sophisticated coordination system between relevant authorities. However, it has some moderate gaps in understanding money laundering and terrorist financing risks. In particular, it does not fully reflect transnational threats and inherent risks associated with being a large financial hub. While authorities cooperate well, Singapore could strengthen its understanding of foreign predicate money laundering risks and pursue more complex transnational cases. Its financial intelligence unit provides useful information to law enforcement agencies.
Semelhante a Mutual Evaluation Ratings Greece 2019 (19)
The document is a mutual evaluation report on Germany's anti-money laundering and counter-terrorist financing measures. It finds that Germany has improved its framework in recent years but some reforms have yet to become fully effective. It rates Germany as having substantial or moderate effectiveness on most outcomes. Key findings include Germany having a good understanding of most risks but some gaps remain, challenges in coordination between states, and room to improve use of financial intelligence and increase prosecution of money laundering cases. Priority actions identified are fully implementing recent reforms, enhancing coordination challenges, and improving availability and use of data across governments.
The document is a mutual evaluation report from April 2021 that assesses New Zealand's anti-money laundering and counter-terrorist financing framework. It provides ratings for New Zealand's level of effectiveness and technical compliance, identifies key strengths and findings, and lists priority actions. Some of New Zealand's strengths identified include understanding money laundering/terrorist financing risks and coordinating domestic actions. Areas for improvement include increasing the availability of beneficial ownership information and ensuring adequate supervision of banks and implementation of targeted financial sanctions.
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1. Anti-money laundering and counter-terrorist financing measures in Greece - Mutual Evaluation Report - September 2019 1
Anti-money laundering and counter-
terrorist financing (AML/CFT)
measures in Greece
Fourth Round Mutual Evaluation
Key findings, ratings and priority actions
September 2019
http://www.fatf-gafi.org/publications/mutualevaluations/documents/mer-greece-2019.html
2. Anti-money laundering and counter-terrorist financing measures in Greece - Mutual Evaluation Report - September 2019
Ratings – Effectiveness (1/3)
2
Immediate outcome of an effective system to combat money
laundering (ML) and terrorist financing (TF)
Extent to
which
Greece has
achieved this
objective
1. ML and TF risks are understood and, where appropriate,
actions co-ordinated domestically to combat ML and TF
Substantial
2. International co-operation delivers appropriate information,
financial intelligence, and evidence, and facilitates action
against criminals and their assets
Substantial
3. Supervisors appropriately supervise, monitor and regulate
financial institutions and designated non-financial
businesses and professions (DNFBPs) for compliance with
AML/CFT requirements commensurate with their risks.
Moderate
4. Financial institutions and DNFBPs adequately apply AML/CFT
preventive measures commensurate with their risks, and
report suspicious transactions.
Moderate
3. Anti-money laundering and counter-terrorist financing measures in Greece - Mutual Evaluation Report - September 2019 3
Immediate outcome of an effective system to combat money
laundering (ML) and terrorist financing (TF)
Extent to
which
Greece has
achieved this
objective
5. Legal persons and arrangements are prevented from misuse
for money laundering or terrorist financing, and information
on their beneficial ownership is available to competent
authorities without impediments
Moderate
6. Financial intelligence and all other relevant information are
appropriately used by competent authorities for money
laundering and terrorist financing investigations.
Substantial
7. Money laundering offences and activities are investigated
and offenders are prosecuted and subject to effective,
proportionate and dissuasive sanctions
Moderate
8. Proceeds and instrumentalities of crime are confiscated. Moderate
Ratings – Effectiveness (2/3)
4. Anti-money laundering and counter-terrorist financing measures in Greece - Mutual Evaluation Report - September 2019 4
Immediate outcome of an effective system to combat money
laundering (ML) and terrorist financing (TF)
Extent to
which
Greece has
achieved this
objective
9. Terrorist financing offences and activities are investigated
and persons who finance terrorism are prosecuted and
subject to effective, proportionate and dissuasive sanctions.
Substantial
10. Terrorists, terrorist organisations and terrorist financiers are
prevented from raising, moving and using funds, and from
abusing the non-profit sector.
Moderate
11. Persons and entities involved in the proliferation of weapons
of mass destruction are prevented from raising, moving and
using funds, consistent with the relevant United Nations
Security Council Resolutions.
Substantial
Ratings – Effectiveness (3/3)
5. Anti-money laundering and counter-terrorist financing measures in Greece - Mutual Evaluation Report - September 2019 5
Ratings – Effectiveness
September
2019
6. 27-Aug-19
6
Ratings – technical compliance
(1/5)
AML/CFT POLICIES AND COORDINATION
1. Assessing risks & applying a risk-based approach LargLarLarLar Largely Compliant
2. National cooperation and coordination LargLarLarLar Largely Compliant
MONEY LAUNDERING AND CONFISCATION
3. Money laundering offence ComCo ComCom Compliant
4. Confiscation and provisional measures LargLarLarLar Largely Compliant
TERRORIST FINANCING AND FINANCING OF PROLIFERATION
5. Terrorist financing offence LargLarLarLar Largely Compliant
6. Targeted financial sanctions related to terrorism & terrorist
financing LargLarLarLar Largely Compliant
7. Targeted financial sanctions related to proliferation LargLarLarLar Largely Compliant
8. Non-profit organisations Part Pa ParPar Partially Compliant
7. 27-Aug-19
7
Ratings – technical compliance
(2/5)
PREVENTIVE MEASURES
9. Financial institution secrecy laws ComCo Co Co Compliant
Customer due diligence and record keeping
10. Customer due diligence ComCo Co Co Compliant
11. Record keeping ComCo Co Co Compliant
Additional measures for specific customers and activities
12. Politically exposed persons ComCo Co Co Compliant
13. Correspondent banking Part Pa Pa Pa Partially Compliant
14. Money or value transfer services ComCo Co Co Compliant
15. New technologies LargLarLarLar Largely Compliant
16. Wire transfers LargLarLarLar Largely Compliant
8. 27-Aug-19
8
Ratings – technical compliance
(3/5)
PREVENTIVE MEASURES (continued)
Reliance, Controls and Financial Groups
17. Reliance on third parties LargLarLarLar Largely Compliant
18. Internal controls and foreign branches and subsidiaries ComCo ComCom Compliant
19. Higher-risk countries LargLarLarLar Largely Compliant
Reporting of suspicious transactions
20. Reporting of suspicious transactions ComCo ComCom Compliant
21. Tipping-off and confidentiality ComCo ComCom Compliant
Designated non-financial Businesses and Professions (DNFBPs)
22. DNFBPs: Customer due diligence LargLarLarLar Largely Compliant
23. DNFBPs: Other measures LargLarLarLar Largely Compliant
9. 27-Aug-19
9
Ratings – technical compliance
(4/5)
TRANSPARENCY AND BENEFICIAL OWNERSHIP OF LEGAL
PERSONS AND ARRANGEMENTS
24. Transparency and beneficial ownership of legal persons LargLarLarLar Largely Compliant
25. Transparency and beneficial ownership of legal arrangements LargLarLarLar Largely Compliant
POWERS AND RESPONSIBILITIES OF COMPETENT AUTHORITIES
AND OTHER INSTITUTIONAL MEASURES
Regulation and Supervision
26. Regulation and supervision of financial institutions LargLarLarLar Largely Compliant
27. Powers of supervisors ComComComCo Compliant
28. Regulation and supervision of DNFBPs LargLarLarLar Largely Compliant
Operational and Law Enforcement
29. Financial intelligence units ComComComCom Compliant
30. Responsibilities of law enforcement and investigative
authorities ComComComCo Compliant
31. Powers of law enforcement and investigative authorities ComComComCo Compliant
32. Cash couriers Part ParParPa Partially Compliant
10. 27-Aug-19
10
Ratings – technical compliance
(5/5)
POWERS AND RESPONSIBILITIES OF COMPETENT AUTHORITIES
AND OTHER INSTITUTIONAL MEASURES (continued)
General Requirements
33. Statistics LargLarLarLar Largely Compliant
34. Guidance and feedback LargLarLarLar Largely Compliant
Sanctions
35. Sanctions LargLarLarLar Largely Compliant
INTERNATIONAL COOPERATION
36. International instruments LargLarLarLar Largely Compliant
37. Mutual legal assistance LargLarLarLar Largely Compliant
38. Mutual legal assistance: freezing and confiscation ComComCo Co Compliant
39. Extradition ComComCo Co Compliant
40. Other forms of international cooperation LargLarLarLar Largely Compliant
11. Anti-money laundering and counter-terrorist financing measures in Greece - Mutual Evaluation Report - September 2019 11
Ratings – technical compliance
September
2019
12. Anti-money laundering and counter-terrorist financing measures in Greece - Mutual Evaluation Report - September 2019
Key findings
Greek authorities generally understand the ML/TF
vulnerabilities and risks they face as presented in the NRA
adopted in May 2018. Greece adopted a national AML/CFT
Action Plan based on the findings of the NRA. Generally, the
objectives of most Greek authorities are consistent with
identified ML/TF risks and national AML/CFT policies. The
National Strategy Committee plays a significant role in
effective co-operation and co-ordination at the national
policymaking levels in Greece. However, Greece had not yet
finalised its national AML/CFT Strategy at the time of the
on-site visit.
Greek authorities effectively use financial intelligence and
other information to develop evidence and trace proceeds
in investigations for ML, TF, and associated predicate
offences. Input from HFIU is regularly sought by LEAs in the
course of their investigations.
12
September 2019
13. Anti-money laundering and counter-terrorist financing measures in Greece - Mutual Evaluation Report - September 2019
Key findings
April 2019
13
HFIU, SSFECU/SDOE and Greek LEAs actively investigate
suspicions of ML and related predicate offences, including
parallel financial investigations and complex investigations
involving organised criminal groups and cross-border activities.
However, once these cases are submitted to prosecutors and
become subject to judicial process, cases encounter undue
delays. The need, in practice, to prove a predicate offence
beyond a reasonable doubt in order to demonstrate the illegal
origin of funds limits the ability to detect, prosecute, and convict
for different types of ML, particularly foreign predicates,
professional money launderers, or money launderers who bear
no relation to the underlying offence. Too little information
regarding sanctions imposed upon conviction for ML was
available to determine whether sanctions are proportionate and
dissuasive.
14. Anti-money laundering and counter-terrorist financing measures in Greece - Mutual Evaluation Report - September 2019
Key findings
14
April 2019
Greek authorities make effective use of tools for seizing and
freezing assets, depriving criminals of illicit proceeds and
preserving assets for future confiscation. However, delays in
prosecution and appellate processes prevent effective
confiscation in many cases, and lack of comprehensive statistics
prevents Greece from demonstrating the degree to which
criminals are permanently deprived of their assets. Sanctions for
false or non-declaration of cash or BNI is not proportionate or
dissuasive.
In Greece, TF activities are effectively identified and investigated,
counter-terrorism investigations all include a financial component
and asset freezing is effectively used to disrupt financial flows,
even in the absence of a TF conviction. Greek authorities have
conducted a limited number of TF prosecutions but has obtained
two convictions in the court of first instance. This is generally in
line with Greece’s context and TF risk profile. However, sanctions
do not appear to be proportionate or dissuasive.
15. Anti-money laundering and counter-terrorist financing measures in Greece - Mutual Evaluation Report - September 2019
Key findings
15
September 2019
Greece effectively deprives assets related to terrorism
through domestic designations for the targeted financial
sanctions (TFS) and has frozen a wide range of assets.
However, limited understanding among certain DNFBPs and
their supervisors hinders effective implementation. Greece
has not yet conducted a comprehensive TF risk assessment
to determine the vulnerability of NPO sectors. This results
in a lack of risk-based supervision over NPOs.
Greece has in place an adequate TFS regime to combat
Proliferation Financing (PF), although no PF-related assets
have yet been identified or frozen. Effective co-operation
and co-ordination between Customs and law enforcement
authorities domestically and internationally contributes to
identifying smuggling of items related to proliferation.
16. Anti-money laundering and counter-terrorist financing measures in Greece - Mutual Evaluation Report - September 2019
Key findings
16
September 2019
Financial institutions (FI) have a reasonably good understanding
of their AML/CFT obligations and ML/TF risk. They adequately
implement preventive measures in a risk-sensitive manner. On
the other hand, understanding of ML/TF risks and the obligations
is limited among DNFBPs, and therefore their implementation is
not robust enough. This gap has been observed in the number of
STR filing among the sectors: reports by the DNFBPs is very low in
general.
The supervisory authorities in the financial sector have a good
understanding of the risks in the financial sector and in individual
firms, and they apply a risk based approach to their supervision
in general. However, a lack of adequate resources has hindered
their capacity to use full range of supervisory tools, e.g. on-site
inspection. There are gaps in the understanding of ML/TF risk
among the DNFBP supervisors. Sanctions beyond fines are rarely
imposed across the financial and non-financial sectors.
17. Anti-money laundering and counter-terrorist financing measures in Greece - Mutual Evaluation Report - September 2019
Key findings
17
September
2019
Basic information on legal persons established in Greece is maintained
mostly by the commercial registry, the General Electronic Commercial
Registry (GEMI), and is publicly available. Greece is in the process of
developing its central Beneficial Ownership Registry, to facilitate the
authorities’ swift access to beneficial ownership information. However,
information on Greek registered shipping companies is maintained in a
separate, paper-based registry. This impedes swift access to accurate
and up-to-date information for this higher risk sector, which has
frequent issuance of bearer shares and complex structures established
in offshore locations. At the time of the onsite, there were over 10 000
société anonyme (SA) corporations (active and inactive) with bearer
shares.
Generally, Greek authorities demonstrate a strong commitment to
international co-operation and, on an operational level, HFIU and LEAs,
particularly Customs, generally demonstrate effective co-operation with
international partners. However, delays in judicial processes negatively
impact Greece’s ability to consistently provide or seek timely MLA and
extradition. A lack of comprehensive statistics hinders Greece’s ability
to assess and improve its own effectiveness in relation to MLA,
extradition and international co-operation.
18. Anti-money laundering and counter-terrorist financing measures in Greece - Mutual Evaluation Report - September 2019
Priority Actions for Greece to
strengthen its AML/CFT System
18
September
2019
Greece should identify and fully understand ML/TF risks that arise
independently from predicate offences, finalise and implement its
National Strategy, including by taking the steps set out in its national
Action Plan to address previously identified and emerging risks.
Greece should examine the case management systems, prioritisation of
tasks and allocation of resources among prosecutors and the judiciary
and make such changes as are necessary to address delays in ML and TF
prosecutions, obtaining irrevocable confiscation orders and in making
and executing MLA and extradition requests. To that end, Greece
should also implement revised criminal procedures, including measures
to address the right to adjournment and to allow for extrajudicial
resolution in appropriate cases.
Greece should conduct a comprehensive domestic assessment over the
NPO sector to identify the features and types of subset of NPOs that are
particularly at TF risk, and implement focused supervision in consistent
with the identified risks.
19. Anti-money laundering and counter-terrorist financing measures in Greece - Mutual Evaluation Report - September 2019
Priority Actions for Greece to
strengthen its AML/CFT System
Greece should take the necessary measures to ensure that, in
practice, a predicate offence does not need to be proven beyond a
reasonable doubt in order to prosecute and convict for ML. Greece
should ensure that it can and does pursue ML prosecutions for the
different types of ML consistent with Greece’s risk profile – i.e.
complex ML cases, professional money launderers, and ML related
to foreign predicates.
Greece should ensure that its beneficial ownership register is fully
operational without delay and that information on shipping
companies is integrated into the central electronic registry system.
Greece should raise awareness of TFS obligations related to both TF
and PF among obliged persons, particularly DNFBPs, and ensure that
obliged persons implement TFS without delay by monitoring their
compliance.
19
September 2019
20. Anti-money laundering and counter-terrorist financing measures in Greece - Mutual Evaluation Report - September 2019
Priority Actions for Greece to
strengthen its AML/CFT System
20
September
2019
Greece should ensure appropriate resources are available to
supervisory authorities to allow them to apply a risk-based approach to
their supervision, and it should make full use of the supervisory powers
in sanctioning breaches.
Greece should strengthen the understanding of AML/CFT risks and
obligations among non-banking FIs and DNFBPs, particularly higher-risk
sector, including by providing more sector-specific guidance and
feedback.
Greece should develop more comprehensive national statistics
regarding ML/TF related issues, including prosecutions, convictions,
MLA and international co-operation, and ensuring sufficient detail to
enable Greece to evaluate their results, identify the difficulties and, if
needed, make necessary improvements.
Greece should review the level of sanctions that are applied upon
conviction for ML and TF and for false or non-declaration of cross-
border movement of cash and BNI to ensure that such sanctions are
effective, proportionate and dissuasive.