|Legal System and Related Institutional Measures|
|2.1 Criminalisation of Money Laundering (R.1 and 2)||• Although the change to article 218-3 appears to satisfy international standards, the Monégasque Authorities should consider revising it with regard to the lower limit required by the European regulation.|
• The authorities should ensure that all designated categories of offence are covered, including the financing of terrorism within the overall meaning of the recommendations and the interpretative note.
• The authorities should clarify the level of proof in the predicate offence.
• The law should permit the intentional element of the offence of ML to be inferred from objective factual circumstances.
• To facilitate the setting up of the new provision, the authorities should consider issuing a manual presenting the AML/CFT law and information on the laundering offence (definition, typology, material elements, intentional element, level of proof required etc.).
• The authorities should accelerate the internal process and extend the criminal liability to legal persons in the Criminal Code.
|2.2 Criminalisation of Terrorist Financing (SR.II)||• The authorities should review the FT definition and clarify its legal framework so that the FT offences can apply to any person who, by any means, directly or indirectly, unlawfully and willfully provides or collects funds, with the intention that they should be used or in the knowledge that they are to be used, in full or in part by a terrorist organization or an individual terrorist.|
• The offences should not require that the funds are linked to one or several specific terrorist acts.
• The law should permit the intentional element to be inferred from objective factual circumstances.
• Art. 391-6 of the Criminal Code should be reviewed to ensure that the family members of a terrorist are liable in case of implication.
|2.3 Confiscation, freezing and seizing of proceeds of crime (R.3)||• The authorities should authorize in internal law the confiscation of property of corresponding value that belongs to the launderers assets if the proceed of crime or its reuse are no longer possible.|
• The authorities should consider the possibility to establish in internal law an independent confiscation procedure to permit in national law, after investigation, the confiscation of legacy values separate from the prosecution of an offender or a foreign confiscation judgment.
• The authorities should consider the possibility to establish mechanisms in internal law to reverse the burden of proof at least for seized values that are susceptible to belong to a criminal organisation or to be controlled by them.
|2.4 Freezing of funds used for terrorist financing (SR.III)||The evaluators recommend to the Monégasque authorities to review the existing legal framework and to take all complementary measures:|
• To ensure that the freezing of assets and other values belonging to persons and entities defined, the Comité des Sanctions (S/RES/1267 – 1999) can intervene without further notice.
• To give the Principality efficient rules and procedures to examine the initiatives taken on behalf of freezing mechanisms of foreign countries et make them effective if the need arises.
• To review the communication system to financial sector of measures taken on behalf of freezing mechanisms (see the best international practice on the freezing of terrorists assets) and its efficiency.
• To give clear instructions to the financial institutions et other persons or entities susceptible to detain funds or other values.
• To ensure that the procedures on listing/delisting and freezing/unfreezing are known by the people.
• To detail the measures concerning the access to the funds to ensure they cover the basic and extraordinary expenses in the sense of the Resolution S/RES/1542 (2002).
• To pursue actively the recognition of the requirements of the Security Council and of the SR.III, and to proceed to an efficient follow-up of the respect of these requirements.
|2.5 The Financial Intelligence Unit and its functions (R.26 & 30)||• The authorities should adapt the law 1162 to put it in accordance with the new art. 218 of the Criminal Code and make SICCFIN able to process and analyze STRs with regard to all the predicate offences that have been established by the new regulation.|
• An explicit legislative or normative enactment should be established concerning SICCFIN or other competent authorities in order to require from the financial institutions or other declaring entities advice on how the declarations should be made. This includes the specification of the forms of the declarations and the procedures to follow if a declaration is made.
• The authorities should review the access of SICCFIN to the information on administrative matters in due time, particularly regarding the information kept by the French customs.
• The authorities should consider taking measures regarding the legal and normative framework of SICCFIN to explicitly formalize within the legislation the set up process that allows it to decide independently on investigation and transmission issues and to suppress every potential interrogation on its autonomy.
• The SICCFIN should complete its annual report and include more information on methods, trends and typologies.
|2.6 Law enforcement, prosecution and other competent authorities (R.27 & 28)||• Given that the repressive system is mostly reactive, the evaluators recommend to the authorities to take measures to analyze the reasons of such a practice and to find a solution relevant to the Monégasque context.|
• The authorities should consider adopting guidelines to assist the authorities in their investigations.
• In the context of the modification of the Criminal Procedure Code, the authorities should introduce provisions that allow the competent authorities to postpone or waive the arrest of suspected persons and/or the seizure of the money for the purpose of identifying persons involved in such activities or for evidence gathering.
• The authorities should also ensure that the introduction of special investigative techniques will allow the law enforcement authorities to use the main techniques – such as means of technical control of telecommunication, of internet and mail, and also special investigation means – when they investigate on AML/CFT issues.
• The authorities should ensure that the law enforcement authorities, the FIU and the other competent authorities work jointly and on a regular basis on the methods, techniques and trends of ML and FT in the Principality of Monaco and that the issuing results and analyses circulate between the staff of the law enforcement authorities and the other competent authorities.
|2.7 SR. IX Cross border declaration and disclosure||• The authorities should set up procedures of systematic transmission of the data concerning the official reports on violation of the cross-border transportation of currency, or bearer negotiable instruments on the Monégasque or French territory susceptible of interesting SICCFIN or the judicial authorities of the Principality, and on the results of the declarations and the controls that have been made.|
• The authorities should set up a system to collect statistical data in order to be able to control the effectiveness of the system, considering that this is implemented by the competent French authorities.
• Lastly, the authorities should review the setting up of the SR. IX in its entirety and to take measures, if the need arises in co-operation with the French authorities, to ensure its setting up having regard to all the essential criteria.
|Preventive Measures – Financial Institutions|
|3.1 Risk of money laundering or terrorist, financing||No action recommended|
|3.2 Customer due diligence, including enhanced or reduced measures (R. 5 to 8)||Recommendation 5:|
• Additional measures should be introduced by the Monégasque authorities to prevent any anonymous financial transactions using bearer treasury and other short term bonds (though their use is very limited).
• The Monégasque authorities should modify the formulation of the obligation to identify the usual customers, so that this disposition applies explicitly and with certainty to every person with whom business relationships are entered into, independently of the opening of an account.
• The verification modalities of the identity of occasional customers wishing to make a wire transfer valued at under € 15,000 should be clearly defined by binding provisions.
• The elements on which the identification of trusts is based should be more accurate and should indicate more clearly for the concerned entities who has to be identified during a trust identification.
• The Monégasque provisions should be adapted to include, as beneficial owners, the persons who have no share of the capital but still provide the leadership of or “brains behind” a company and persons who have established trusts.
• Without reconsidering the fact that every financial institution, as far as it is concerned, is obliged to define the most appropriated concrete modalities of identification of high risk situations that require an increased vigilance, and jointly with the threshold of € 100,000 above which the vigilance regarding the clients operations needs to be reinforced, the Monégasque authorities should define what conditions these individual systems should satisfy to be considered as adequate. The Monégasque authorities should publish in particular guidelines concerning the setting up of the risk-based approach referred to in art. 5, al.2, 4th and 5th dashes of the OS.
• The provisions that are in force concerning the increased vigilance should be completed to specify the additional responsibilities to which the entities are bound, beyond the obligation to proceed to a new customer identification.
• Though the Monégasque authorities maintain that the financial institutions are not allowed, other than in situations specified in law, to exercise simplified diligence in situations that they themselves have identified as low risk, the wording of the regulations does not unambiguously exclude this possibility.
• The provisions authorizing a lower level of diligence for customers that are public companies do not require them to be subject to the laws of countries that comply with and apply the FATF recommendations.
• The provisions authorizing a lower level of diligence for customers that are financial institutions subject to the legislation or public companies do not stipulate exceptions when there are suspicions of money laundering or terrorist financing.
• The authorities should complete the notion of PEP by presenting recommendations inspired of the glossary definition of the 40 Recommendations of the FATF to indicate more precisely the specified functions.
• The Monégasque authorities should complete the applicable provisions on correspondent banking to allow, in particular, that:
• The obligation to collect sufficient covers checks on whether the institution concerned has been investigated or the subject of action by the AML/CFT supervisory body.
• The conclusion of correspondent banking relationships requires financial establishments to assess client institutions’ and reference to checks on their suitability or efficacy.
• The approval from senior management is required before establishing new correspondent banking relationships.
• The respective AML/CFT responsibilities of the Monégasque and client institutions have to be set down in writing within the framework of banking representation relationships.
• The competent Monégasque authorities should establish guidelines or recommendations for the Monégasque financial institutions concerning the appreciation of the equivalence of the legislation and of the controls that are applicable on AML/CFT issues in the country where the foreign institution is established.
• The existing measures should be completed to include the obligation for financial institutions to establish policies or procedures to deal with the misuse of new technologies for money laundering or terrorist financing purposes. This point could seem of particular relevance on the supposition that the restrictions to which the financial institutions are submitted regarding the use of new technologies to transactional purposes should be relaxed.
|3.3 Third parties and introducers (R.9)||• An enforceable legal rule should be established, requiring Monégasque financial institutions to ensure that third party business generators have satisfied all the due diligence requirements in FATF Recommendation 5.|
• The competent authorities should issue instructions or recommendations on how to assess the equivalence of AML/CFT legislation and controls to be applied in countries where foreign client institutions are based (see R.7).
|3.4 Secrecy laws consistent with the Recommendations (R.4)|
|3.5 Record keeping and wire transfer rules (R.10 & SR. VII)||Recommendation 10:|
• The Monégasque authorities should complete the provisions concerning the data and record keeping to explicitly provide for the required period for the retention of documents relating to transactions to be extended of requested by the competent authority in specific cases, if it is necessary to carry out their responsibilities. The same applies to the retention in writing of identification information, accounting documentation and commercial correspondence.
• The law or regulation should as well be complemented in order to specify that data and documents must be maintained in a form that makes it possible to reconstruct individual transactions and provide evidence in the case of prosecution.
Special Recommendation VII:
• The existing provisions should be completed to specify the arrangements for verifying the identity of occasional customers who seek the services of a Monégasque financial institution to carry out a wire transfer valued at under € 15,000.
• The Monégasque framework should be completed to submit the application of simplified communication measures of information concerning the ordering party within the framework of routine international transfers that are not batched (exception not provided in SR.VII) to additional binding conditions guaranteeing sufficiently no misuse of this exception.
|3.6 Monitoring of transactions and relationships (R.11 & 21)||Recommendation 11:|
• The legal framework should be reviewed so that the size of transactions and their complexity or abnormality should be alternative rather than cumulative criteria for determining whether financial institutions should be required to show increased diligence, also the Monégasque authorities.
• The Monégasque authorities should provide for enforceable measures requiring increased diligence in connection with business relationships or transactions with counterpart institutions with links to countries that do not properly apply the FATF Recommendations.
|3.7 Suspicious transaction reports and other reporting (R.13-14, 19, 25 & SR IV)||Recommendation 13:|
• The Monégasque legal framework should be completed so that all designated categories of offences, as defined by the FATF, can apply in all circumstances, whether or not they result from organised criminal activity.
• It should furthermore be adapted so that the reporting requirement in Monégasque legislation does not cover all suspicious transactions, such as attempted operations that have failed for reasons other than that the financial institution has refused to carry out the transaction.
• No recommended action.
• No recommended action.
• The competent Monégasque authorities should complete the instructions and recommendations they have addressed to the financial institutions to assist them more systematically on all the main issues that the application of preventive measures is likely to raise in practice.
• The authorities should ensure the implementation of mechanisms guaranteeing the organisations and individuals concerned by this information ready and rapid access to information regarding methods and trends of ML and the evolution of the phenomena (especially through the dissemination of the results of the liaison committee’s activities).
• Given the professional confidentiality of SICCFIN staff, it is necessary that the Monégasque authorities examine whether the adoption of specific legal provisions would enable to provide a more comprehensive and systematic specific feedback to financial institutions on action taken on suspicious transactions that they have reported.
Special Recommendation IV:
• The Monégasque law should be completed so that the reporting requirement also extends to attempted operations that have failed for reasons other than that the financial institution has refused to carry out the transaction, in particular because customers themselves decide not to continue with a transaction after first having requested it.
|3.8 Internal controls, compliance audit and foreign branches (R. 15 & 22)||Recommendation 15:|
The legal framework should be completed (at least concerning the financial institutions others than banks) so that:
• The officer or employee in charge of suspicious transaction reporting does not have overall responsibility by law for the organisation and internal control of AML/CFT measures within the financial undertaking.
• It is required that the financial institution gives him the status and powers to enable him to fulfil his duties.
• The law or regulations give him an access to all necessary information.
• These financial institutions be explicitly required to maintain an independent internal control function, endowed with sufficient resources, entailing sanctions for non-compliance.
Apart from the criteria for issuing work permits, the existing device should be modified to enable the financial institutions to verify the honesty of candidates for employment before they are hired.
• Article 13 of Law 1162 of 7 July 1993 should be modified to extend all of Monaco’s legislation and regulations on prevention to subsidiaries and branches located abroad, and require from those to pay special attention to compliance with the relevant principles in the case of subsidiaries and branches located in countries which do not or which insufficiently apply the FATF Recommendations.
• The legislation and regulations should also require that where the minimum standards applicable in Monaco differ from those of the country where a branch or subsidiary is located, the most stringent legislation should then be applied.
• Monaco’s law should also require financial undertakings to inform SICCFIN if the local legislation or regulations applicable to their subsidiaries or branches does not authorise the application of the preventive measures in force in Monaco as a whole.
|3.9 Shell banks (R. 18)||• The evaluators recommend to the authorities to ensure the effectiveness of the new law on this matter.|
|3.10 The supervisory and oversight system – competent authorities and STRs (Role, functions, duties and powers (including sanctions)) (R.23, 29, 17 & 25)||• The authorities should establish an action plan to reinforce significantly and the sooner the exercise of the control function on financial institutions.|
• The Monégasque preventive framework should be extended to mutual fund management companies.
• The Monégasque framework should also be modified so that the insurance intermediaries (brokers and agents) shall be explicitly subject to it.
• The Monégasque authorities should consider completing the range of administrative sanctions (notably by establishing the possibility of administrative fine) to improve its progressiveness and to allow a more proportionate application of the sanctions to the seriousness of the violation identified (cf. R17).
• The Monégasque authorities should consider completing the range of administrative sanctions (notably by establishing the possibility of administrative fine) to improve its progressiveness and to allow a more proportionate application of the sanctions to the seriousness of the violation identified.
• The Monégasque authorities should consider modifying the system of applicable sanctions so that, beyond the criminal penalties provided for in Articles 32 and 33 of the law, sanctions can be imposed on senior managers and employees of financial undertakings for violations of AML/CFT obligations.
• No action is recommended concerning the control function of SICCFIN.
• The competent Monégasque authorities should complete the instructions and recommendations they have addressed to the financial institutions to assist them more systematically on all the main issues that the application of preventive measures is likely to raise in practice.
|3.11 Money value transfer services (SR.VI)||• Apart from the statutory provisions applying generally to exercise of economic or commercial activities in the Principality, specific provisions should be introduced in Monaco legislation laying down the conditions for the exercise of money transfer services.|
|Preventive Measures – Non Financial Businesses and Professions|
|4.1 Customer due diligence and record keeping (R. 12)||• The Monégasque authorities should put a stop to the legal uncertainty that comes from the decision of annulation No. 14.466 of 22 April 2000 pronounced by the Supreme Court the 6 March 2001, as it only points out the lawyers. They should ensure that the lawyers are subject to the preventive obligations provided for in the Recommendation 12 of the FATF.|
• The legal framework applicable to the casinos should be completed so that:
• They are required to ensure that the customers are acting on their own behalf or on behalf of effective beneficiaries.
• They are required to determine which of their customers are PEPS and to submit their relationships with such customers to enhanced monitoring.
Other DNFBPs (in particular real estate agents, dealers in precious metals and precious stones, notaries, legal and tax advisers and other independent accounting professions) should:
• Be subject to due diligence with regard to customers and their transactions in accordance with FATF Recommendations 5, 6, 8, 9 and 11.
• Be required to keep customer identification and transaction records in accordance with FATF Recommendation 10.
• In the case of casinos and other businesses and professions covered by article 2 of the law, the legislation and regulations should be completed so that the violation of the obligations here above mentioned can be subject to sanctions, and so that these sanctions can be imposed not only to the natural person or person who can be held liable for the criminal offence but also to the gaming house or business itself.
• In the case of casinos, the applicable framework should be completed so that breaches of requirements in matters of customer due diligence or organization and implementation of preventive procedures can constitute grounds for imposing an enforcement measure or sanction, except where it can be proved that the breaches resulted in a failure to report suspicious transactions, liable to criminal penalties.
• The limitation of the financial activities of the SFE to those that are in relation with the games provided by the motherhouse (SBM) results from the practice, and is not based on legislation, regulations or statutory rules. The Monégasque authorities should establish this limitation of the activities of the SFE on a certain legal basis.
|4.2 Suspicious transaction reporting (R. 16)||Regarding all DNFBPs:|
• The applicable framework should be modified so that the reporting requirement covers all the underlying offences referred to in FATF Recommendation 1, independently of the commission or not by a criminal organisation.
• The applicable framework should be modified so that the undertaking or business in the framework of which the suspicious transaction has been carried out can be liable for an administrative penalty for the failure to report the transaction, even though the statutory conditions for imposing the criminal sanction provide for in Article 32 of the law have not been satisfied, or where the facts are not sufficiently serious to warrant such a criminal sanction.
• The Monégasque authorities should have recourse to binding and enforceable measures to lay down special vigilance measures regarding business relationships or transactions with counterparties having links with countries which fail to apply or insufficiently apply the FATF Recommendations.
Regarding CSPs and trustees:
• The applicable framework should be modified so that the reporting requirement laid down in Monaco legislation can cover attempted transactions which have not taken place for any reason other than a refusal by the financial undertaking to carry out the transaction, including cancellation of the transaction by the requester himself or herself.
Regarding CSPs, trustees and casinos (cf. Section 3.8.3):
• All the above mentioned recommended actions in 3.8 should be put in place.
Regarding casinos and other DNFBPs:
• The applicable legislation or regulations should be modified so that these businesses and professions can be subject to the obligation to report a suspicious transaction, whether when the professional in question has refused to carry out the transaction, or in the case of a transaction which does not go ahead for whatever reason, including cancellation by the individual concerned.
Regarding other DNFBPs:
• The applicable legislation or regulations should be modified so that organisational or internal control measures are put in place, following criterion 16.1, in accordance with FATF R. 15.
• The applicable legislation or regulation should be modified so that SICCFIN can be kept informed about suspicious transaction reports filed by the notaries with the Principal State Prosecutor and of the subject matter of such reports.
|4.3 Regulation, supervision and monitoring (R.24-25)||Recommendation 24:|
• Regarding the CSPs and the trustees, additional means should be put at the disposal of SICCFIN to allow it to increase significantly the frequency of the on-site controls.
• Additional means should also be allocated to SICCFIN, jointly with the enlargement of the preventive obligations of DNFBPs, to allow this authority to exercise effectively its on-site control missions and of the respect of the obligations of these businesses and professions.
• Parallel to the recommended extension of the preventive obligations for the DNFBPs (see 4.1 and 4.2), the competent Monégasque authorities should circulate instructions and recommendations able to provide a systematic assistance on all main issues that the application of preventive measures is likely to raise in practice; more on that issue in 3.10.
|4.4 Other non-financial businesses and professions (R.20)|
|Legal Persons and Arrangements & Non-Profit Organisations|
|5.1 Legal Persons – Access to beneficial ownership and control information (R.33)||• The authorities should consider satisfying the recommendations formulated in the report concerning the beneficial owners and the control of legal persons and introduce a surveillance framework of the service providers to the undertakings, imposing them to verify and keep the adequate, exact and updated information concerning the beneficial owners and the structure of control of the legal persons.|
|5.2 Legal Arrangements – Access to beneficial ownership and control information (R.34)||• The procedure put in place should allow to record all necessary information concerning ownership and control of trusts (settler, administrator, beneficiary, protector).|
• The information being held should be exact and updated. Thus the provisions concerning the updating of the list kept by the Court of Appeal should be reviewed.
• The authorities should take measures so that the competent authorities can obtain in relevant time adequate, exact and updated information on the beneficial owners and on the control of trusts, in particular on persons who created the trusts, the administrator and the beneficiaries.
|5.3 Non-profit organisations (SR. VIII)||• The authorities should consider reviewing the adequacy of their laws and regulations and include a formal assessment of risks potential misuse of these institutions for terrorist financing purposes.|
• Taking into consideration the actual process of reviewing the whole legislation concerning associations and foundations, the authorities should ensure that the draft laws contain the measures of the best international practices concerning SR VIII, in particular regarding transparency and control.
• The authorities should review the actual legal framework to ensure that comprehensive information on activities, size and other aspects relevant to this sector are up to date and available.
• The authorities should consider reinforcing the staff taking care of the issues concerning this sector.
• The authorities should take measures to sensitize the NPOs to the terrorist financing issues.
|National and International Co-operation|
|6.1 National Co-operation and coordination (R.31)||• The Monégasque authorities should reinforce their co-operation and coordination with the French customs at national level.|
• The authorities should consider taking measures to increase the collaboration with other control authorities.
|6.2 The Conventions and UN Resolutions (R.35 & SR.I)||Recommendation 35:|
• It is important that the Principality takes additional measures to carry out effectively the legislation and regulations (incrimination, criminal liability for legal persons, special techniques of investigation) and to take measures to treat the cross-border cash transfer issues (Articles 15,17 and 19 of the Vienna Convention et Article 7.2 of the Palermo Convention);
Special Recommendation I:
• It is important that the Principality ensures the effectiveness of the measures taken related to SR III.
• The authorities should furthermore reconsider the reservations that were formulated on the Convention on laundering, search, seizure and confiscation of the proceeds of crime.
|6.3 Mutual Legal Assistance (R.36-38, SR.V)||• The authorities should put in place mutual legal assistance mechanisms, notably through internal laws and through bilateral co-operation, allowing the foreign judicial authorities to request the largest co-operation from the Monégasque judicial authorities.|
• The authorities should develop the network of bilateral and multilateral international co-operation treaties to facilitate the execution of the active international assistance in the national procedures in order to obtain proves that are abroad.
• The authorities should introduce a legal basis and rules of procedures to allow the use of special techniques of investigation in the framework of the international co-operation.
• The authorities should remove the pre-condition of prepaid expense by the requesting state to freeze the funds.
• The authorities should consider creating a special fund to receive the confiscated assets based on foreign judgements that are not restored or shared.
• It is important that the Principality ensures the possibility to give assistance concerning the financing of a terrorist organisation or of a terrorist.
|6.4 Extradition (R.37 &39, & SR V)||• The Principality should sign and ratify the European Convention on extradition and intensify the network of bilateral conventions.|
• It is important that the Principality ensures the possibility to extradite for all financing of terrorism violations.
|6.5 Other Forms of Co-operation (R.40 & SR V)||• The authorities should modify Article 31 of the Law 1162 not to limit the scope of information exchanges and ensure that it is possible in relation with money laundering and predicate offences.|
• The authorities should modify Article 31 to explicitly implement the possibility of spontaneous communications with other FIUs.
• The authorities should review the legislation and regulations on exchange with the foreign control authorities in order to allow a wide international co-operation.
|7.1 Resources and Statistics (R. 30 &32)||Recommendation 30:|
• The Monégasque authorities should review the resources of the police responsible of financial investigations pointing at violations that generate important proceeds, to reinforce the effectiveness of the confiscation mechanism.
• The resources, notably human, left at the disposal of SICCFIN to fulfil its on-site control mission on the financial institutions should be significantly increased so that the effectiveness of this function can be reinforced.
• The authorities should conduct an assessment of the number of staff within the public prosecution service and the investigative judges' offices, taking into account the total number of cases of economic and financial crime, with a view to envisaging an increase in staff numbers if necessary.
• The authorities should ensure that the rotation system of the magistrates does not affect the effectiveness and the continuity of investigations on AML/CFT issues.
• The authorities should review the legal framework to remove all uncertainties or interrogations about the level of independence and autonomy of the investigative and prosecution authorities.
• The authorities should keep comprehensive statistics on investigations and prosecutions (including the reasons of a non-conviction) and convictions, allowing to distinguish the cases of laundering committed by the author of the predicate offence.
• The authorities should ensure the effectiveness of the Monégasque confiscation regime.
• The competent authorities should keep comprehensive annual statistics on the declarations concerning physical cross-border transportation of currency or bearer negotiable instruments and international wire transfers.
• The SICCFIN should implement in its statistics information on the predicate offences and on the closed cases, for a best understanding of the methods, trends and typologies of laundering acts after the coming into force of the new provisions.
• The authorities should keep more detailed statistics to demonstrate the effectiveness of the prosecution authorities' action.
• The authorities should keep comprehensive statistics concerning the implementation of SRIX.
• The statistics concerning the mutual assistance should be completed to allow a more global vision of all requests received by the Director of the Judicial Services relating to money laundering, to predicate offences and to terrorist financing, including the nature of the request, whether it was granted or refused and the time required to respond.
• The authorities should keep comprehensive statistics on the mutual assistance requests concerning money laundering, predicate offences and terrorist financing.
• Comprehensive statistics should be kept by the FIU on the spontaneous sending of information.
|7.2 Other measures and relevant subjects on AML/CFT issues||-|
|7.3 General structure of the AML/CFT system – Elements of structural nature||-|