money laundering best practices, lessons to be learnt and steps

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egistration of Exchange Offices. The Law does not prescribe licensing and registration for otherfinancial institutions.In spite of the requests set forth in Recommendation 24, Croatian Legislation does not seecasinos as a specific subject that would need a separate and more rigid regulatory system andtreats them regularly. As such, they have the same duties and obligations on reporting suspicioustransactions as banks, as set forth in Art 2 of the Law on Prevention of Money Laundering.Croatian Office for Prevention of Money Laundering is not compelled by Law to provideinformation feedback to any financial institution or designated non-financial business orprofession on reported suspicious transactions. However, in the past few years, on its owninitiative, the Office has provided such information on reported transactions to banks. Still, it hasnot been happening on a regular basis and can not be observed as a trend.The Rulebook on the Implementation of the Law in Art 12 Para 2 regulates the obligation of theOffice to compile a list of indicators for recognizing suspicious transactions. There are four setsof guidelines as follows: banking sector, lawyers and accountants, casinos and exchange offices.In accordance with Recommendation No 26, which regulates establishment of the FinanceIntelligence Unit, Republic of Croatia established the Office for Prevention of MoneyLaundering. The Office operates within the Ministry of Finance, Financial Police. It collects,processes, analyses and stores data received from obligatories, and provides the information tothe relevant authorities, which the Office uses to undertake measures for prevention of moneylaundering. The Office, Financial Police and Ministry of Internal Affairs work together veryclosely in the implementation of measures for prevention of money laundering. 16The Office for Prevention of Money Laundering has direct access to the tax authorities, butaccording to the information from the Office, this access is not used very frequently. In itsinvestigations, the Office, more often explores indirect approaches.16Art 3 of the Law on Prevention of Money LaunderingMoney Laundering Best Practices,Lessons to be Learnt in the Balkan RegionWritten by Tamara BrneticPage 25 of 58
Pursuant to Recommendation No 27, Croatian Law foresees the Ministry of Interior, i.e. thepolice, as the body that will, along with their other duties, also conduct investigations on moneylaundering and financing of terrorism. However, Croatian Law does not foresee any specialinvestigative techniques for these criminal acts apart from the techniques already available to thepolice. There is no additional public information on investigative techniques in Croatia.As already explained in Recommendation No 27, the police, i.e. Ministry of Interior, as aninvestigative body, uses the State Attorneys Office in order to gain any information required forthe investigation. That includes acquiring documents and information needed in theirinvestigations, as well as for the criminal prosecutions or similar activities.In accordance with Recommendation No 29, Croatian Legislation in Art 21a of the Law onPrevention of Money Laundering defines relevant bodies for the supervision of subjects bound byLaw as follows: Croatian National Bank, and Croatian Agency for FinancialTransactions(HANFA). Article 19 of the Rulebook on the Implementation of the Law explicitlystates that at least once a year subjects are obliged to perform internal audit on theimplementation of the Law and inform in writing the authorized person and the Office. Externalcontrol is within the competence of the Croatian National Bank, as it isdefined in the Law as therelevant state body.Croatian Legislation does not provide for compliance with FATF Recommendation No 30.However, the state has set up a set of employment standards used for recruiting into state bodies,but unfortunately there are no special standards for bodies involved with prevention of moneylaundering. As well, the law does not foresee any check of the moral and integrity of employees.The Law on Prevention of Money Laundering and the Rulebook on its Implementation do notregulate or in any way guide the cooperation of bodies engaged in the prevention of MoneyLaundering, so one can say there is no compliance with Recommendation No 31. However,according to unofficial information from the Office, they cooperate through the Office.Money Laundering Best Practices,Lessons to be Learnt in the Balkan RegionWritten by Tamara BrneticPage 26 of 58
Page 1 and 2: Money Laundering Best Practices, Le
Page 3 and 4: INTRODUCTIONThere is a saying that
Page 5 and 6: Historically, money laundering beca
Page 7 and 8: promotion of the rule of law has to
Page 9 and 10: MONEYVALMoneyval was formerly known
Page 11 and 12: purchases. There were import/export
Page 13 and 14: Croatia has a preventive system est
Page 15 and 16: In a well known case which took pla
Page 17 and 18: Proceedings and Law on Office for P
Page 19 and 20: However, the Law does not provide f
Page 21 and 22: The last amendments of the Law on P
Page 23 and 24: Croatian Law on Prevention of Money
Page 25: duties they suspect that transactio
Page 29 and 30: the condition of reciprocity. Croat
Page 31 and 32: Croatia is in full compliance with
Page 33 and 34: there is no information on independ
Page 35 and 36: overwhelming model of creation of o
Page 37 and 38: Bosnia also has a wide spread probl
Page 39 and 40: On 19 November 2003, the Macedonian
Page 41 and 42: antiquities, theft of cargo of a ve
Page 43 and 44: about unusual transactions from a v
Page 45 and 46: abroad to the account of an offshor
Page 47 and 48: prostitution, trafficking in weapon
Page 49 and 50: PONZI’S SCHEMESOne of the very co
Page 51 and 52: foreign currency debt amounts to DM
Page 53 and 54: POSSIBILITIES FOR MONEY LAUNDERERS
Page 55 and 56: to launder monthly, so he starts to
Page 57 and 58: work abroad bring the money into th
Page 59: 24. http://www.vreme.com/cms/view.p

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