The assessment was conducted by: Mr. José Luis Fernández Valoni (legal expert), Ministry of Foreign Affairs, International Trade and Worship, Argentina; Mr. Fernando Mera Espinosa (law enforcement expert), Responsible for the Money Laundering Office at the Superintendence of Banks and Insurance of Ecuador; Mrs. Maria Célia Ramos (financial expert), Senior Legal Counsel, Legal Department, Banco de Portugal; Mr. John C. Ellis (financial expert), Adviser, Money Laundering Policy, Financial Crime Policy Unit, Financial Services Authority (FSA), United Kingdom; Mr. Fernando Rosado, Executive Secretary, GAFISUD; Ms. Silvina Capello, GAFISUD Secretariat; Mr. Patrick Moulette, Executive Secretary, FATF; and Mr. Kevin Vandergrift, FATF Secretariat.
As of 3 November 2003, the exchange rate was BRL 1 = USD .349.
In December 2003, the National Anti-Money Laundering Strategy group (ENCLA, which involves all the relevant ministries and agencies established the goal of developing a system to provide nationwide statistics on money laundering investigations, indictments, and convictions, under the coordination of the Justice Department’s Department of Assets Recovery and International Legal Co-operation (DRCI).
Brazil ratified the UN Convention against Transnational Organised Crime on 29 January 2004 and promulgated it by Decree 5015 of 12 March 2004.
The Justice Ministry’s Department of Assets Recovery and International Legal Co-operation (Departamento de Ativos e Cooperação Jurídica Internacional—DRCI) was formally established by Decree 4991 of 18 February 2004. One of its main tasks is to maintain improved statistics in this area.
See previous footnote.
SUSEP Circular 249/2004 was issued on 20 February 2004. It purportedly obliges insurance companies, capitalisation companies, and open pension funds entities to establish, internal controls (including an internal audit) by 31 December 2004. The examination team has not evaluated the Circular.