Structure of this report
This report provides a summary of the regulatory
regime and key cases in each country, the estimated
size of the regulated sector and the extent of
compliance and enforcement activity in each
jurisdiction.
The second section describes the AML/CTF
legislative regime in each of the nine countries. It
includes the criminal provisions for money laundering
and the financing of terrorism, as well as the basis
of the preventative regulatory measures in place
for each country. The structure of the financial
intelligence unit, the scope of the regulated sector,
the obligations to submit financial intelligence
reports, the inclusion of tipping-off provisions
and the basis of the required compliance programs
are discussed. Less focus is placed on specific
customer identification requirements, record keeping
provisions and ongoing customer due diligence. A
detailed discussion of emerging areas of concern,
such as the use of informal banking systems and
charities for money laundering and terrorism
financing activities, is also beyond the scope of
this report. These areas, however, are noted where
countries regulate them for AML/CTF purposes.
The second section also provides some
consideration of case law arising from money
laundering convictions and sanctions applied for
non-compliance with AML/CTF regulations. The
focus is on prosecutions and other events specifically