money laundering best practices, lessons to be learnt and steps

Sanader explained that he did not know how to fill in the property card, but until now there is noofficial explanation on their origin 15 .Taking everything into account, it should be said that although Croatian legislation provides forpartial compliance with FATF Recommendation No 6, there is great room for improvement inthis field.Croatia does not have anything included in the Law on Prevention of Money Laundering or anyother way to regulate the requirements set out in FATF Recommendation No 7. According torecent information, it is included in the draft of the new Law that will be send for first readingbefore the Parliament in early 2008. At this time, all subjects are passing the same identificationrequirements by financial institutions and the same rules are applied for reporting suspicioustransactions to the Office for Prevention of Money Laundering, which then initiates appropriatedetailed in-depth investigation of the subject on an “as needed” basis.Furthermore, Croatian Legislation does not regulate in any way any of the requirements from theFATF Recommendations No 8 and 9. In depth analysis is expected to be included in the new Lawon Prevention of Money Laundering.On the basis of Art 16 of the Law on Prevention of Money Laundering and in compliance withRecommendation No 10, all bodies bound by law have to store data gained on the basis of thisLaw, and documentation on the basis of which the transaction was completed for at least fiveyears from the day of its completion, even more from the last of several linked transactions unlessit is otherwise foreseen by the Law. Additionally, the same article regulates the storing ofinformation on the party with whom the body bound by law (subject) had a business relationshipof a more permanent nature and requires storing of information for at least five years.The Law in Articles 8 and 11 defines the Office for Prevention of Money Laundering as thecompetent body authorised to request any data on the transaction from the subject of the law.15Glas Istre, 11. siječanj 2007http://www.mojevijesti.com/story/1931/title/Pingpong-oko-Sanaderovih-satova-u-OtvorenomMoney Laundering Best Practices,Lessons to be Learnt in the Balkan RegionWritten by Tamara BrneticPage 19 of 58