money laundering best practices, lessons to be learnt and steps

(subject) must inform the Office before they actually perform the transaction about the time whenit will take place. They are obliged to pass the written notification within three days in case theyinformed the office by phone. Note on the transaction has to be written and registered in case ofverbal notification. However, in case that the body bound by law (subject) is not in the position toinform the office in time, due to the nature of the transaction, it is obliged to do the same within24 hours after the transaction was completed at latest. Art 11 also foresees that state bodies, localself governance and other legal persons with public authorities are obliged to submit data neededfor discovering of money laundering to the Office.Croatian Law on Prevention of Money Laundering does not explicitly say that FinancialInstitutions and their employees are protected from civil and criminal liability for breach of thelimitations of disclosing argument determined in the contract when they are bona fide informingthe Office as requested in Recommendation No 14., as it says they are obliged to inform theOffice in cases already prescribed and whenever they suspect money laundering activity. TheLaw in Chapter IV also provides for the confidentiality of the collected information.Subjects of the Law are obliged to finance regular and permanent education of their employees inaccordance with FATF Recommendation 15 and as foreseen in the Rulebook on Implementationof the Law on Prevention of Money Laundering. Also, the financial institution is obliged toinform and educate its employees in new techniques of performing transactions and about waysof notifying the Office. The Rulebook also determines in Art 19 that financial institutions areobliged to perform internal audit on the implementation of the Law.Croatian Law does not prescribe any special standards in employment in order to secure highstandards. As put forward in Art 16 of the Rulebook, requirements are set only for the profile ofthe person dealing with money laundering examinations. The Rulebook is not clear whether thesame standards should be applied to the two deputies. The requirements are set to: Croatiancitizenship, clear of criminal investigation or prosecution, three years of experience in relevantwork field, knowledge in business of financial institutions, relevant education. In para 2 of thesame Article the Rulebook leaves space for the financial institution to set up its own additionalrules.Money Laundering Best Practices,Lessons to be Learnt in the Balkan RegionWritten by Tamara BrneticPage 21 of 58