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.
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.
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.
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.
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.
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
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 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.
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.
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.
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.
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.
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
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 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 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.
The document is a mutual evaluation report from April 2018 that assesses Iceland's anti-money laundering and counter-terrorist financing regime. It finds that Iceland has a basic understanding of risks but its national risk assessment is theoretical rather than based on factual threats. Coordination of competent authorities is limited. Financial intelligence is used for some cases but several impediments remain. No terrorist financing prosecutions have occurred and authorities do not consider terrorist financing vulnerabilities. Key priority actions identified include revising the risk assessment, improving coordination, increasing guidance to reporting entities, and establishing a framework for targeted financial sanctions.
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.
This document is a mutual evaluation report on anti-money laundering and counter-terrorist financing measures in Thailand from December 2017. It provides key findings, ratings, and priority actions. Thailand demonstrates a substantial understanding of ML/TF risks and international cooperation, but its preventive measures, supervision of businesses, and ability to prevent misuse of legal persons are rated as low. The report outlines Thailand's progress in AML/CFT reforms and coordination but identifies gaps in assessing sector and TF risks and applying risk mitigation measures. It recommends Thailand improve pursuit of ML investigations and targeting of key risk areas like corruption.
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 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.
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.
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 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.
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 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 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.
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 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 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.
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.
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.
This document is a mutual evaluation report from April 2020 that assesses the UAE's anti-money laundering and counter-terrorist financing framework. It finds that while the UAE has made significant improvements to its AML/CFT system, many changes are recent and their effectiveness has yet to be fully realized. It provides ratings for the UAE's technical compliance and effectiveness in 11 immediate outcomes. Overall compliance and effectiveness were rated as moderate, though some areas like targeting of proliferation financing were rated low.
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 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 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.
The document is a mutual evaluation report from April 2018 that assesses Iceland's anti-money laundering and counter-terrorist financing regime. It finds that Iceland has a basic understanding of risks but its national risk assessment is theoretical rather than based on factual threats. Coordination of competent authorities is limited. Financial intelligence is used for some cases but several impediments remain. No terrorist financing prosecutions have occurred and authorities do not consider terrorist financing vulnerabilities. Key priority actions identified include revising the risk assessment, improving coordination, increasing guidance to reporting entities, and establishing a framework for targeted financial sanctions.
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.
This document is a mutual evaluation report on anti-money laundering and counter-terrorist financing measures in Thailand from December 2017. It provides key findings, ratings, and priority actions. Thailand demonstrates a substantial understanding of ML/TF risks and international cooperation, but its preventive measures, supervision of businesses, and ability to prevent misuse of legal persons are rated as low. The report outlines Thailand's progress in AML/CFT reforms and coordination but identifies gaps in assessing sector and TF risks and applying risk mitigation measures. It recommends Thailand improve pursuit of ML investigations and targeting of key risk areas like corruption.
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 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.
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.
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 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.
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 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 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.
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 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 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.
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.
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.
This document is a mutual evaluation report from April 2020 that assesses the UAE's anti-money laundering and counter-terrorist financing framework. It finds that while the UAE has made significant improvements to its AML/CFT system, many changes are recent and their effectiveness has yet to be fully realized. It provides ratings for the UAE's technical compliance and effectiveness in 11 immediate outcomes. Overall compliance and effectiveness were rated as moderate, though some areas like targeting of proliferation financing were rated low.
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 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.
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 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 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.
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 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 is a mutual evaluation report on anti-money laundering and counter-terrorist financing measures in Mauritania. It finds that Mauritania has a low level of effectiveness in 11 immediate outcomes related to combating money laundering and terrorist financing. It also rates Mauritania as non-compliant or partially compliant on most technical compliance requirements, with low levels of implementation and enforcement of its anti-money laundering and counter-terrorist financing system.
The document is a mutual evaluation report on Nicaragua's anti-money laundering and counter-terrorist financing measures. It finds that Nicaragua has legal and regulatory frameworks and institutions to combat money laundering and terrorist financing, but that the current legal framework has some deficiencies that limit effectiveness. It rates Nicaragua's level of achievement in various areas and its technical compliance with Financial Action Task Force recommendations. Key findings include that understanding of risks is uneven, intelligence is used to identify assets but reporting of suspicious transactions needs a legal basis, and deficiencies in criminalizing terrorist financing affect effectiveness.
The document is a mutual evaluation report on anti-money laundering and counter-terrorist financing measures in Fiji. It finds that while Fiji has reasonable cooperation between agencies on AML/CFT policies, there are gaps in its understanding of risks. It also finds that legal persons and beneficial ownership information present challenges. Priority actions identified include improving risk assessments, increasing resources for investigation agencies, and remedying deficiencies in the terrorist financing offense and targeted financial sanctions framework.
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.
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.
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.
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.
The document is a mutual evaluation report on Mongolia's anti-money laundering and counter-terrorist financing measures. It finds that Mongolia faces threats from money laundering related to crimes like fraud, environmental crimes, and corruption. Terrorist financing risks are limited. Mongolia achieved low effectiveness for most outcomes related to preventing and investigating these issues. It identifies that Mongolia needs to improve understanding of risks, apply its national risk assessment, and better use financial intelligence.
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.
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.
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.
Semelhante a Mutual Evaluation Ratings Turkey 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 on anti-money laundering and counter-terrorist financing measures in Pakistan from October 2019. It provides ratings on Pakistan's effectiveness and technical compliance in various areas. For effectiveness, Pakistan was rated as low for 11 immediate outcomes related to understanding risks, supervision, applying preventive measures, investigating offenses, and preventing terrorist financing. For technical compliance, Pakistan received largely compliant, partially compliant and non-compliant ratings for 40 recommendations across several domains including criminalization, preventive measures, and international cooperation.
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.
This document is a mutual evaluation report on Haiti's anti-money laundering and counter-terrorist financing measures. It finds that Haiti achieved low effectiveness in 11 immediate outcomes related to combating money laundering and terrorist financing. On technical compliance, Haiti was rated non-compliant or partially compliant on most recommendations, particularly regarding risk assessment, targeted financial sanctions, and transparency of legal persons and arrangements. Supervision and regulation of financial institutions and DNFBPs was also found to be non-compliant.
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.
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.
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.
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North East Atlantic Fisheries Commission (NEAFC)
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South East Atlantic Fisheries Organisation (SEAFO)
South Pacific Regional Fisheries Management Organisation (SPRFMO)
Southern Indian Ocean Fisheries Agreement (SIOFA)
Western and Central Pacific Fisheries Commission (WCPFC)
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1. Anti-money laundering and counter-terrorist financing measures in Turkey - Mutual Evaluation Report - December 2019 1
Anti-money laundering and counter-
terrorist financing (AML/CFT)
measures in Turkey
Fourth Round Mutual Evaluation
Key findings, ratings and priority actions
December 2019
http://www.fatf-gafi.org/publications/mutualevaluations/documents/mer-turkey-2019.html
2. Anti-money laundering and counter-terrorist financing measures in Turkey - Mutual Evaluation Report - December 2019
Ratings – Effectiveness (1/3)
2
Immediate outcome of an effective system to combat money
laundering (ML) and terrorist financing (TF)
Extent to
which
Turkey 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 Turkey - Mutual Evaluation Report - December 2019 3
Immediate outcome of an effective system to combat money
laundering (ML) and terrorist financing (TF)
Extent to
which
Turkey 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.
Moderate
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 Turkey - Mutual Evaluation Report - December 2019 4
Immediate outcome of an effective system to combat money
laundering (ML) and terrorist financing (TF)
Extent to
which
Turkey 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.
Moderate
10. Terrorists, terrorist organisations and terrorist financiers are
prevented from raising, moving and using funds, and from
abusing the non-profit sector.
Low
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.
Low
Ratings – Effectiveness (3/3)
5. Anti-money laundering and counter-terrorist financing measures in Turkey - Mutual Evaluation Report - December 2019 5
Ratings – Effectiveness
December
2019
0
2
7
2
High
Substantial
Moderate
Low
6. 11-Dec-19
6
Ratings – technical compliance
(1/5)
AML/CFT POLICIES AND COORDINATION
1. Assessing risks & applying a risk-based approach Largely compliantLargely compliantLargely compliantLargely compliantLargely compliant
2. National cooperation and coordination Largely compliantLargely compliantLargely compliantLargely compliantLargely compliant
MONEY LAUNDERING AND CONFISCATION
3. Money laundering offence Largely compliantLargely compliantLargely compliantLargely compliantLargely compliant
4. Confiscation and provisional measures CompliantCompliantCompliantCompliant Compliant
TERRORIST FINANCING AND FINANCING OF PROLIFERATION
5. Terrorist financing offence Largely CompliantLargely CompliantLargely CompliantLargely CompliantLargely Compliant
6. Targeted financial sanctions related to terrorism & terrorist
financing Partially compliantPartially compliantPartially compliantPartially compliantPartially compliant
7. Targeted financial sanctions related to proliferation Non compliantNon compliantNon compliantNon compliant Non compliant
8. Non-profit organisations Partially compliantPartially compliantPartially compliantPartially compliantPartially compliant
7. 11-Dec-19
7
Ratings – technical compliance
(2/5)
PREVENTIVE MEASURES
9. Financial institution secrecy laws CompliantCompliantCompliantCompliant Compliant
Customer due diligence and record keeping
10. Customer due diligence Largely compliantLargely compliantLargely compliantLargely compliantLargely compliant
11. Record keeping CompliantCompliantCompliantCompliant Compliant
Additional measures for specific customers and activities
12. Politically exposed persons Non compliantNon compliantNon compliantNon compliant Non compliant
13. Correspondent banking Largely compliantLargely compliantLargely compliantLargely compliantLargely compliant
14. Money or value transfer services Largely compliantLargely compliantLargely compliantLargely compliantLargely compliant
15. New technologies Largely compliantLargely compliantLargely compliantLargely compliantLargely compliant
16. Wire transfers Largely compliantLargely compliantLargely compliantLargely compliantLargely compliant
8. 11-Dec-19
8
Ratings – technical compliance
(3/5)
PREVENTIVE MEASURES (continued)
Reliance, Controls and Financial Groups
17. Reliance on third parties CompliantCompliantCompliantCompliant Compliant
18. Internal controls and foreign branches and subsidiaries Partially compliantPartially compliantPartially compliantPartially compliantPartially compliant
19. Higher-risk countries Largely compliantLargely compliantLargely compliantLargely compliantLargely compliant
Reporting of suspicious transactions
20. Reporting of suspicious transactions CompliantCompliantCompliantCompliant Compliant
21. Tipping-off and confidentiality CompliantCompliantCompliantCompliant Compliant
Designated non-financial Businesses and Professions (DNFBPs)
22. DNFBPs: Customer due diligence Partially compliantPartially compliantPartially compliantPartially compliantPartially compliant
23. DNFBPs: Other measures Partially compliantPartially compliantPartially compliantPartially compliantPartially compliant
9. 11-Dec-19
9
Ratings – technical compliance
(4/5)
TRANSPARENCY AND BENEFICIAL OWNERSHIP OF LEGAL
PERSONS AND ARRANGEMENTS
24. Transparency and beneficial ownership of legal persons Partially compliantPartially compliantPartially compliantPartially compliantPartially compliant
25. Transparency and beneficial ownership of legal arrangements Partially compliantPartially compliantPartially compliantPartially compliantPartially compliant
POWERS AND RESPONSIBILITIES OF COMPETENT AUTHORITIES
AND OTHER INSTITUTIONAL MEASURES
Regulation and Supervision
26. Regulation and supervision of financial institutions Partially compliantPartially compliantPartially compliantPartially compliantPartially compliant
27. Powers of supervisors Largely compliantLargely compliantLargely compliantLargely compliantLargely compliant
28. Regulation and supervision of DNFBPs Partially compliantPartially compliantPartially compliantPartially compliantPartially compliant
Operational and Law Enforcement
29. Financial intelligence units CompliantCompliantCompliantCompliant Compliant
30. Responsibilities of law enforcement and investigative
authorities CompliantCompliantCompliantCompliant Compliant
31. Powers of law enforcement and investigative authorities Largely compliantLargely compliantLargely compliantLargely compliantLargely compliant
32. Cash couriers Largely compliantLargely compliantLargely compliantLargely compliantLargely compliant
10. 11-Dec-19
10
Ratings – technical compliance
(5/5)
POWERS AND RESPONSIBILITIES OF COMPETENT AUTHORITIES
AND OTHER INSTITUTIONAL MEASURES (continued)
General Requirements
33. Statistics Largely compliantLargely compliantLargely compliantLargely compliantLargely compliant
34. Guidance and feedback Largely compliantLargely compliantLargely compliantLargely compliantLargely compliant
Sanctions
35. Sanctions Partially compliantPartially compliantPartially compliantPartially compliantPartially compliant
INTERNATIONAL COOPERATION
36. International instruments Largely compliantLargely compliantLargely compliantLargely compliantLargely compliant
37. Mutual legal assistance CompliantCompliantCompliantCompliant Compliant
38. Mutual legal assistance: freezing and confiscation CompliantCompliantCompliantCompliant Compliant
39. Extradition CompliantCompliantCompliantCompliant Compliant
40. Other forms of international cooperation Largely compliantLargely compliantLargely compliantLargely compliantLargely compliant
11. Anti-money laundering and counter-terrorist financing measures in Turkey - Mutual Evaluation Report - December 2019 11
Ratings – technical compliance
December
2019
12. Anti-money laundering and counter-terrorist financing measures in Turkey - Mutual Evaluation Report - December 2019
Key findings
Turkey finalised a combined ML/TF risk assessment in 2018
The NRA was a significant step in enhancing Turkey’s
understanding of ML/TF risk. Relevant authorities contributed
to the process, with positive input from the private sector.
Turkish authorities have a general understanding of ML. This
understanding is greater than that represented in the NRA. TF
risk is understood well by key agencies such as TNP and
MASAK. This understanding of ML/TF would benefit from
overarching, formal strategies and policies to combat ML/TF.
Authorities have commenced work in these areas.
There are demonstrable mechanisms for co-ordination in
place, although their effectiveness for AML/CFT purposes is
mitigated to some extent, as AML/CFT co-ordination has not
been brought together under a single whole-of-government
policy approach, which is both risk-based and demonstrably
co-ordinates measures taken.
12
December 2019
13. Anti-money laundering and counter-terrorist financing measures in Turkey - Mutual Evaluation Report - December 2019
Key findings
Turkey has demonstrated the use of MASAK’s financial intelligence
products to support ongoing investigations and prosecution of
predicate, ML and TF offences. MASAK’s work has increased many fold
since the attempted coup in 2016 with an exponential rise in judicial
requests from public prosecution and courts, which has caused strains
on the capacity of AML/CFT authorities. The extent to which financial
intelligence is used routinely in existing ML cases or developing
evidence across all the law enforcement agencies is not demonstrated.
Turkey’s law enforcement agencies have trained and dedicated
investigators. However, identifying ML activity for investigation
through their analysis of STRs and other reports submitted to MASAK,
or through investigation of offences generating proceeds of crime is
not commensurate with the risk profile in Turkey. While Turkey does
not have detailed statistics on ML investigations by predicate offence,
they provided statistics for the four highest risk predicate offence
supported with a sampling of cases, which suggests that ML offences
and activities are investigated to some extent.
December 2019
13
14. Anti-money laundering and counter-terrorist financing measures in Turkey - Mutual Evaluation Report - December 2019
Key findings
Turkey has an adequate legal framework that should enable the
authorities to confiscate the proceeds of crime through a number of
measures, but limited statistical figures or other evidence were
provided by Turkey to fully demonstrate the good use of these tools.
However, after the attempted coup in 2016, Turkey enacted temporary
measures, which were effectively implemented against FETÖ/PDY.
Although Turkey has demonstrated the existence of high-level
commitment to deprive criminals from their proceeds of crime, its
practical impact to ensure that criminals are permanently deprived of
their illicit gains is less evident.
Turkey undertakes a large number of terrorism investigations; however,
TF investigations within these cases are largely directed towards
identifying the assets held rather than the identification of the
collection, movement and use of funds or other assets. Outside of
FETÖ/PDY investigations, there is limited evidence that public
prosecutors have used MASAK analysis to extend their investigation to
include the bigger networks.
14
December 2019
15. Anti-money laundering and counter-terrorist financing measures in Turkey - Mutual Evaluation Report - December 2019
Key findings
Turkey does not implement terrorism related TFS without delay under the
relevant UNSCRs. Turkey’s legal framework allows for UNSCR 1267 designations
to be transposed, however the transposition process leads to long delays. In
general, there is collaboration and co-operation on TF issues between
supervisory, regulatory and operational authorities, co-ordinated by MASAK.
However, Turkey has never independently proposed a 1267 designation or
enacted a domestic designation, nor identified assets linked to a designation
target. Turkey does not use 1373 processes effectively, which is not consistent
with its risk profile.
As part of its 2018 NRA, Turkey has conducted a sectorial risk assessment to
identify the FATF-defined subset of NPOs that are at risk of TF abuse. However,
Turkey’s supervision of the NPO sector is mainly focused on fraud and
mismanagement, instead of TF and Turkey’s outreach and oversight efforts
remain lacking.
As with TF-related TFS, Turkey’s transposition of UNSCR 1718 designations into
law is not without delay, and no assets subject to UNSCR 1718 sanctions have
ever been identified in Turkey. Turkey lacks a legal basis to implement UNSCR
2231 and its successor resolutions, and no penalties or oversight exist for
contravention of these PF sanctions by obliged entities in Turkey, as 2231
designations are not legally valid.
15
December 2019
16. Anti-money laundering and counter-terrorist financing measures in Turkey - Mutual Evaluation Report - December 2019
Key findings
Understanding of ML/TF risks across FIs and DNFBPs varies. While banks
have a good understanding of ML risks, and by some way the best
understanding among the reporting entities, the understanding of TF
risk is relatively weaker than that for ML. The level of understanding of
ML/TF risks across DNFBPs is limited. Across all reporting entities, the
understanding is less developed among real estate agents, DPMS and
exchange offices, which is a cause of concern in light of their risk
profiles.
The supervisory measures, including fit and proper tests applied by
BRSA, CMB and MoTF for the licensing of banks and other FIs, were
found to be generally well developed for the purpose of preventing
criminals and their associates from entering the financial system.
Supervision and monitoring to address and mitigate ML/TF risks in the
financial sector and other relevant sectors has led to remedial actions;
however, sanctions applied are not always effective, proportionate and
dissuasive.
16
December 2019
17. Anti-money laundering and counter-terrorist financing measures in Turkey - Mutual Evaluation Report - December 2019
Key findings
Understanding of ML/TF risks across FIs and DNFBPs varies. While banks
have a good understanding of ML risks, and by some way the best
understanding among the reporting entities, the understanding of TF
risk is relatively weaker than that for ML. The level of understanding of
ML/TF risks across DNFBPs is limited. Across all reporting entities, the
understanding is less developed among real estate agents, DPMS and
exchange offices, which is a cause of concern in light of their risk
profiles.
The supervisory measures, including fit and proper tests applied by
BRSA, CMB and MoTF for the licensing of banks and other FIs, were
found to be generally well developed for the purpose of preventing
criminals and their associates from entering the financial system.
Supervision and monitoring to address and mitigate ML/TF risks in the
financial sector and other relevant sectors has led to remedial actions;
however, sanctions applied are not always effective, proportionate and
dissuasive.
17
December 2019
18. Anti-money laundering and counter-terrorist financing measures in Turkey - Mutual Evaluation Report - December 2019
Key findings
Turkey has put in place most elements of a legal framework to identify
basic and beneficial ownership information of legal persons. The
concept of trusts does not exist in Turkish law. Authorities have a
moderate understanding of the ML/TF risks posed by legal persons, and
are yet to conduct a comprehensive assessment of ML/TF risks and
vulnerabilities of legal persons created in Turkey.
Turkey has a sound legal basis to provide and seek the widest possible
range of MLA, including extradition in relation to ML, associated
predicate offences and TF. Turkey does not have any legal impediments
to seeking and responding to a variety of requests for international co-
operation both formal and informal.
18
December 2019
19. Anti-money laundering and counter-terrorist financing measures in Turkey - Mutual Evaluation Report - December 2019
Priority Actions for Turkey
to strengthen its AML/CFT System
Turkey should prioritise the use of financial intelligence
related to ML, consistent with the risks identified in their
NRA and develop a national strategy for investigating and
prosecuting different types of ML offences.
Turkey should develop a national strategy for confiscating the
proceeds and instrumentalities of crime, outlining clear
priorities as well as the roles and responsibilities for
prosecutor, LEAs and MASAK.
Turkey should address the gaps in its legal framework to fully
meet its obligations concerning targeted financial sanctions
related to terrorism. In particular, transposition of UN
designations should be done in a timely manner that is not
contingent upon a decision at national level. Turkey should
ensure it is employing its resources to independently identify
and propose appropriate targets for 1 267 designation and
respond to 1 373 requests.
19
December 2019
20. Anti-money laundering and counter-terrorist financing measures in Turkey - Mutual Evaluation Report - December 2019
Priority Actions for Turkey
to strengthen its AML/CFT System
Turkey should address deficiencies in its timely
transposition of UNSCR 1718 and immediately establish a
legal basis to implement UNSCR 2231 and its successor
resolutions, including the establishment of effective,
proportionate and dissuasive sanctions and requirements
for corresponding supervision and preventive measures in
the financial sector.
Turkey should implement focused and proportionate
measures to NPOs identified as at risk of TF abuse. A
targeted risk-based approach and outreach on how to
identify, prevent and report TF, with a focus on those NPOs
assessed as higher risk for potential TF abuse would help
avoid restricting and disrupting legitimate NPO activities.
20
December 2019
21. Anti-money laundering and counter-terrorist financing measures in Turkey - Mutual Evaluation Report - December 2019
Priority Actions for Turkey to
strengthen its AML/CFT System
21
December 2019
Turkey should increase the number of parallel financial
investigations in terrorism cases with the objective of
identifying terrorist financiers, TF trends and methods, and
financing networks.
The supervisory approach of the authorities to DNFBP
sectors, in particular, for precious metals and stones and
real estate sectors should be developed and these sectors
should be subject to AML/CFT compliance proportionate to
their risk profiling as per the NRA. Sanctions for non-
compliance by financial institutions and DNFBPs should be
effective, proportionate and dissuasive.