The assessment was conducted by Mr. Juan Antonio Aliaga Mendez, financial expert from the Ministry of Economy and Finance, Spain; Ms Elisabeth Florkowski, financial expert from the Financial Market Authority, Austria; Mr. Paolo Guiso, legal expert from the Ufficio Italiano dei Cambi, Italy; Mr. Donald P. Merz, law enforcement expert from the Internal Revenue Service, United States of America and Mr. Vincent Schmoll and Ms. Catherine Marty from the FATF Secretariat.
Section 129a(1) StGB
Meantime, the German legislative bodies have adopted a new legislation prior to the ratification of the UN International Convention for the Suppression of the Financing of Terrorism.
A new section of the KWG which came into force in November 2003 has closed this loophole. The new provision will cover the cases of financial sanctions against terrorists residing within the European Union.
KWG - Kreditwesengesetz - Banking Act as amended on 21 August 2002
GwG - Geldwaschegesetz - Money Laundering Act as amended on 8 August 2002
LKA - Land Criminal Police Office in charge of police matters
The last amendment became effective on 15 August 2002
Although the information on the existence of a general system of feedback was not delivered during the on-site visit or during the elaboration of the Mutual Evaluation Report, it was eventually delivered during the finalisation of the ROSC.