Crypto Assets and Property of the Bankruptcy-Estate: An Analysis

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Anti-Money Laundering Regulations In 2022 & ID 2020

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ANTI-MONEY LAUNDERING – Understanding the Global IN 2022

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EXCLUSIVE – WORLD BANK Participant-List EXPOSED – Original Document

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Top 10 most Corrupt Countries of the World - Still Buddy
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Pandora Papers Unveals The Arabian Money Machine

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UAE's Sheikhs Tahnoon, Hazza and Maktoum

From left, Sheikh Tahnoon bin Zayed, Sheikh Hazza bin Zayed Al Nahyan and Sheikh Mohammed bin Rashid Al Maktoum.

Citation:”One of the many reasons the Pandora Papers have been so groundbreaking is its scope. By investigating files leaked from 14 different offshore service providers — who operate in jurisdictions far beyond the island tax havens of popular imagination — our reporting broke new ground on well-known destinations in the offshore world, as well as rising ones.

One of those places is the United Arab Emirates. The Pandora Papers provides an unprecedented look at how Dubai’s rise as one the world’s financial capitals coincided with the growth of its shadow economy — as a secrecy haven that’s become a nexus for money laundering and other financial crimes.

In our latest investigation, ICIJ’s Cairo-based reporter Maggie Michael and senior editor Michael Hudson delve into the UAE’s thriving trade in financial secrecy. Months of reporting revealed the real owners of secretive UAE-based companies, which include alleged gold smugglers, internet moguls who moved hundreds of millions of dollars for child porn traffickers, heroin dealers, and other lowlifes. nth.

The Pandora Papers investigation also sheds light on the unique role that the country’s six royal families play in the UAE’s economy and offshore industry, and why Dubai has so far escaped the kind of pressure seen by other tax havens like the British Virgin Islands and Switzerland.

The leaked files also show how the UAE has become a go-to offshore destination for many African elites. ICIJ’s Will Fitzgibbon’s reporting uncovers the secretive Emirati financial interests of politicians and corporate leaders from 17 African countries.

We’ve added new politicians to our Power Players interactive, exposing the offshore holdings of the UAE president’s son and adviser, Sultan bin Khalifa Al Nahyan, “spy sheikh” Tahnoon bin Zayed Al Nahyan, the family of Kazakhstan’s longtime former ruler, a former ambassador from South Sudan and an Angolan media minister.

U.S. lawmakers cite a Pandora Papers investigation by the Washington Post and ICIJ in calling for the Biden administration to investigate the mistreatment of sugar cane workers in the Dominican Republic.

German authorities are seeking the arrest of Swiss attorney Christoph Zollinger, a former senior employee at Panama Papers law firm Mossack Fonseca, who played a key role in some of the firm’s most controversial decisions.

The Denver Museum of Art will turn over four ancient statues to the U.S. government, which plans to return them to their native Cambodia, weeks after Pandora Papers reporting revealed links between relics in the museum’s collection and a notorious indicted art dealer.

Thanks for reading!

Asraa Mustufa

ICIJ’s digital editor

P.S. If you’ve enjoyed our coverage this week, remember to tell your friends and family and share our work on social media. Send them an email now!

End of Citation

LEAKED: Deutsche Bank Court Papers – FRAUD – MONEY LAUNDERING – Fine Of $55 Million – Original Document

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RUSSEL BRAND – Another “Conspiracy Theory” CONFIRMED – Secrets Of The SUPER RICH EXPOSED!!!

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New documents called Pandora Papers, have been released to reveal that the rich live by different rules to the public. Hugely wealthy figures & politicians have had their money secrets revealed… #PandoraPapers #Tax #Billionaires


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AOC’s attendance at the Met Gala with her statement dress ‘Tax The Rich’, has caused controversy as this act could just be another political gesture without any intention of true change. #MetGala #PoliticalGesture #TaxTheRich

Person Convicted To 11 Years For Money Laundering For North Korea

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THE ONLY WEBSITE WITH THE LICENSE TO SPY! > North Korea p66a: 5000 Won from 2002

Ghaleb Alaumary, a 36-year-old dual U.S and Canadian citizen, worked for cyber criminals including the three North Koreans who heisted as much 1.3 billion dollars in a cybercrime spree believed to be executed on behalf of North Korean intelligence.Among the victims of the spree was a major Maltese bank, the Bank of Valletta, which was robbed of $14 million in 2019. To turn that cash into usable currency, the hackers turned to Alaumary.

“Alaumary recruited and organized individuals to withdraw stolen cash from ATMs; he provided bank accounts that received funds from bank cyber-heists and fraud schemes; and, once the ill-gotten funds were in accounts he controlled, Alaumary further laundered the funds through wire transfers, cash withdrawals, and by exchanging the funds for cryptocurrency,” the DOJ explained.

The North Korean spree employed other high-profile money launderers, including the Nigerian social media influencer Ramon “Hushpuppi” Abbas.

Before working with the North Koreans, Alaumary was implicated as an accomplice in the theft of $9.4 million from Canada’s McEwan University.

According to the DOJ, Alaumary worked with others to convince the university that they represented a construction company who had been involved in a major building project at the school, ultimately defrauding the school into wiring the team millions.

In addition to the jail time, Alaumary has also been ordered to pay more than $30 million to his victims in restitution.

“Other victims of Alaumary’s crimes included banks headquartered in India, Pakistan and Malta, as well as companies in the United States and U.K., individuals in the United States and a professional soccer club in the U.K.,” the DOJ said.

US Court Action Vs North Korean Hackers & Their Cryptomoney Accounts – Original Document

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Commentary: Making sense of North Korea's hacking strategy | Reuters
Page 1 of North Korea Hacking & Cryptocurrency
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TOP SECRET – The U.S. Treasury About Russian Oligarchs

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Department of the Treasury, Russia
U.S. Treasury Report Identifying Russian Senior Foreign Political Figures and Oligarchs
February 19, 2018
Report to Congress Pursuant to Section 241 of the Countering America’s Adversaries Through Sanctions Act of 2017 Regarding Senior Foreign Political Figures and Oligarchs in the Russian Federation and Russian Parastatal Entities
Page Count: 9 pages
Date: January 29, 2018
Restriction: None
Originating Organization: Department of the Treasury
File Type: pdf
File Size: 653,958 bytes
File Hash (SHA-256): 7B075365AF3BBA0A5CDA1C1E3E296620F8DB3B37745C119238B9E1E0335DD47A


Section 241 of the Countering Americaメ s Adversaries Through Sanctions Act of 2017 (???TSA) requires the Secretary of the Treasury, in consultation with the Director of National Intelligence and the Secretary of State, to submit to the appropriate congressional committees 180 days after enactment ? detailed report ?? senior political figures and oligarchs in the Russian Federation (Section 241 (a)(l)) and on Russian parastatal entities (Section 241 (?)(2)). Pursuant to Section 241(?), the report shall ?? submitted in an unclassified form but may have ? classified annex. This is the unclassified portion of the report.

As required ?? Section 241 (a)( l)(A) of CAATSA, the Department of the Treasury is providing in this unclassified report ? list of senior foreign political figures and oligarchs in the Russian Federation, as determined ?? their closeness to the Russian regime and their net worth. For purposes of this unclassified portion of the report, this determination was made based ?? objective criteria related to individuals ム official position in the case of senior political figures, or ? net worth of $1 billion or more for oligarchs.

?? determine the list of senior political figures, the Department of the Treasury considered the definition in CAATSA Section 24 1 (?)(2), which incorporates ?? reference the definition of モsenior foreign political figureヤ in section 1?10.605 , title 31 of the Code of Federal Regulations. For purposes of this unclassified portion of the report, such names consist of: i) senior members of the Russian Presidential Administration; ii) members of the Russian Cabinet, Cabinet-rank ministers, and heads of other major executive agencies; iii) other senior political leaders, including the leadership of the State Duma and Federation Council, other members of the Russian Security Council, and senior executives at state-owned enterprises. These individuals are listed in Appendix 1 of this report.

CAATSA Section 24 1(?)(2)-(5) requires ? report on Russian parastatal entities, including an assessment of their role in the economy of the Russian Federation; an overview of key U.S. economic sectorsメ exposure to Russian persons and entities; an analysis of the potential effects of imposing additional debt and equity restrictions on parastatal entities; and the possible impact of additional sanctions against oligarchs, senior political figures, and parastatals on the U.S. and Russian economies.

Russian parastatals have origins in the Soviet Unionメs command economy. After the dissolution of the Soviet Union, the Russian government conducted large-scale privatization of these entities; in the early 2000s, it began to renationalize large companies. The Russian government has responded to economic shocks, including the financial crisis in 2008 and the imposition of sanctions in 2014, ?? increasing its role in the economy and ownership of parastatals. As of 2016, Russian parastatals accounted for one-third of all jobs in Russia and 70 percent of Russiaメs GDP.


$ 750 Million Missed in DRC

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A poisonous blend of debasement and bungle in Democratic Republic of Congo’s incomes organizations and state mining organizations is draining a fifth of all mining incomes far from the state spending plan, Global Witness uncovers today. Its report ‘Administration Cash Machine’ demonstrates that in any event $750 million disappeared more than three years – cash that ought to have been utilized on fundamental open administrations for the Congolese individuals.

The discoveries come during a period of extraordinary political turmoil in Congo as the beset President Joseph Kabila sticks to control. “Congo’s mining incomes ought to be lifting its kin out of destitution, yet rather colossal totals are being siphoned far from general society tote and into unaccountable offices headed up by individuals with binds to political elites,” said Pete Jones, Global Witness Senior Campaigner.

Congo is Africa’s best copper maker and the world’s greatest provider of cobalt, which is utilized as a part of the lithium-particle batteries that power electric autos and amidst a value blast. Regardless of this, Congo stays one of the poorest nations on the planet. ‘Administration Cash Machine’ examinations the most recent information from the Extractive Industries Transparency Initiative (EITI), which uncovers that in the vicinity of 2013 and 2015 over $750 million of installments by mining organizations to Congo’s assessment offices and state mining organizations never achieved the national treasury. That figure ascends to a surprising $1.3 billion when other state bodies and a now-outdated commonplace assessment body are incorporated.

“A portion of the exchanges we’ve taken a gander at illustrate these organizations as a money machine for Kabila’s administration”, said Jones. “In the event that Congo is to abstain from losing the faith into strife and disorder, genuine straightforwardness and responsibility is required all through the mining segment and in the assessment organizations,” Jones said.

The discoveries come as Congo slips assist into political vulnerability. The nation is wracked by on-going political brutality and distress, following Kabila’s refusal to venture down from control notwithstanding an established mandate. A key reason for discontent with the administration is the ceaseless absence of subsidizing by the legislature in fundamental administrations, for example, schools, healing centers and streets.

“For quite a long time Global Witness and others have archived how incomes have spilled from Congo’s mining segment into seaward shell organizations. Presently we can see that even incomes paid to government bodies in Congo are disappearing before they achieve the treasury,” Jones included.

A key offender in this preoccupation of assets is the principle state-claimed mining organization, Gécamines. It gets more than a hundred million dollars every year from privately owned businesses in Congo’s mining part, however seems to pass on only a modest rate of that to the state coffers. Gécamines’ most imperative and lucrative business connections are with significant worldwide mining organizations, which regularly have Western financial specialists and benefits tied up in their benefits and dangers.

While its commitments to Congo’s open satchel are little, Gécamines sufficiently discovered cash to pay off immense advances from Dan Gertler, a dear companion of President Kabila. One of Gertler’s organizations was reimbursed in the meantime as Gécamines’ staff went unpaid and more seasoned advances stayed extraordinary.

Congo’s duty offices are likewise to fault. Current law enables them to keep down a rate of the fines they exact, which has prompted ruthless lease looking for conduct and created fines as they try to expand the amount they can keep as their own particular assets. The greater part of this adds up to a type of authorized debasement.

The Congolese constitution expresses that each Congolese individual has the privilege to appreciate the advantages of the nation’s national riches, and that the state has an obligation to redistribute that riches evenhandedly and ensure the privilege to advancement. To by far most of Congolese, those are unfilled words. A long time of fumble and debasement inside Gécamines, consolidated with a divided duty framework, imply that the framework is interested in manhandle by political elites trying to remove money from the mining division.

“The best way to put a conclusion to the redirecting of these indispensable assets is to revamp the divided duty framework and to demand full straightforwardness from Gécamines. We have to know the amount it wins, the amount it pays to the treasury, and what it spends its cash on,” said Jones.

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Exposed – IMF Panama Anti-Money Laundering & Terrorist Financing Report

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  • 99 pages
  • Restricted
  • Confidential
  • January 8, 2007



A. General

This assessment of observance of the Financial Action Task Force (FATF)
Recommendations for anti-money laundering and countering the financing of terrorism (AML/CFT) has been completed as part of an evaluation of Panama’s observance of regulatory standards for the financial sector.


Panama is a constitutional republic with a democratically elected president who is both
chief of state and head of government. The current government began its four-year period in
September 2004. The country has a unicameral legislative assembly, also elected by popular
vote, and an autonomous judicial branch. The legal system is based on the civil law tradition,
with some features of its commercial legislation being influenced by legal institutions of
United States common law (i.e., the regulation of trusts).

With a population of approximately 3 million, Panama has a territory of 78,200 square
kilometers in the Central American isthmus, between the Caribbean Sea and the
North Pacific Ocean, bordered by Costa Rica and Colombia. Full control and operation of the
Panama Canal connecting the Atlantic and Pacific oceans were transferred from the
United States to Panama in 1999. The Canal drives much of Panama’s economy, along with
the Colon Free Trade Zone (ZLC), a booming real estate market and a well developed
services sector, including banking and financial services. Although there is a legal parity
between the local currency (Balboa) and the U.S. dollar, in practice no local currency
circulates and all commercial payments and financial transactions are made in U.S. dollars.
Panama endeavors to provide economic and political leadership in the Central
American and Caribbean region and is a member of many international organizations,
including the Caribbean Financial Action Task Force (CFATF), which it currently presides.
Banking activities represent the most significant component of the financial services
sector. Banking system assets on a nonconsolidated basis were $39.6 billion, and on a
consolidated basis (including local and foreign subsidiaries of Panamanian-headquartered
banks) were $45.8 billion at end-March 2006. At end–March 2006, there were 73 banks,
including 2 state-owned banks, 37 general license private banks, and 34 international license
banks. The banking center in Panama has a significant international presence, including
banks from the United States, the United Kingdom, Spain, and other Latin American and
European countries.

Lawyers and accountants are not required to belong to a professional association in
order to practice, and the associations’ codes of ethics are not legally enforceable. There are ethical rules for lawyers established by law and subject to investigation and sanction by the
Supreme Court, although there have been very few sanctions in practice.
General situation of money laundering and financing of terrorism
Information from various criminal investigations shows that the reporting and other
preventive requirements in the money laundering law have had a dissuasive effect on
money laundering activity in financial institutions. The UAF reported that money
laundering has moved towards other parts of the economy in order for launderers to avoid the
developed capacity of banks to detect the introduction of illicit capital.
The geographic location of Panama makes it an attractive transit area for drugs and
related money laundering. To date, the 10 money laundering cases that have been
prosecuted were based on narcotics-related predicate crimes. The cases have resulted from
internal efforts in the Public Ministry (Ministerio Público) as well as from international
cooperation. Other financial crimes cases have resulted mainly from foreign investigations of
corruption where funds were later deposited in Panamanian financial institutions.
An area of great concern involves the role that the Free Zone of Colón (ZLC), the
second largest free-trade zone in the world, can play as the originating or transshipment point
for goods purchased with proceeds of narcotics trafficking, including through the Black
Market Peso Exchange. The smuggling of currency, drugs, and prohibited chemical
materials, the introduction and transshipment of counterfeit merchandise, and several forms
of customs fraud also generate criminal proceeds that expose the system to money

Officials advised that the Panamanian jungle border with Colombia is occasionally
penetrated by the illegal armed groups active along their common border, but did not
consider this to pose a terrorist threat to Panama. There have been no known cases of
financing of terrorism.

The following are the governmental agencies with direct responsibility on AML/CFT issues in the areas of prevention, regulation, supervision, investigation or prosecution:

• Financial Analysis Unit (UAF), within the National Public Security and National Defense Council of the Ministry of the Presidency;

• Superintendency of Banks (SdB);

• National Securities Commission (CNV);

• Autonomous Panamanian Cooperatives Institute (IPACOOP);

• Ministry of Commerce and Industry (MICI), which includes:

• Superintendency of Insurance and Reinsurance (SSRP);

• National Directorate of Finance Companies (responsible for finance companies, leasing companies, money remitters and pawn brokers);

• Office of Export Processing Zones;

• Real Estate Technical Board;

• Accounting Board (it has no AML/CFT responsibilities at the moment).

• Gaming Control Board of the Ministry of Economy and Finance;

• ZLC Administration;

• Attorney General (Ministerio Público and the judicial technical police within);

• Judicial Branch (no specific courts specialized in money laundering or the financing of terrorism; and

• National Directorate of Immigration.

Criminalization of Money Laundering (R.1 & 2)

Description and analysis

Panama has criminalized money laundering through Articles 389 to 393 of the Penal Code, as adopted through Law 41 of October 2, 2000 and Law 1 of January 5, 2004. This Law 41 amended the previously existing AML law, stating in Article 389 of the Penal Code that, “Whoever receives, deposits, trades, converts, or transfers monies, titles, securities, goods, or other financial resources knowing that the origin of the activities is related with drug trafficking, qualified embezzlement, illegal weapons trafficking, human trafficking, kidnapping, extortion, embezzlement, public corruption, terrorism, robbery, or internal vehicle contraband established in the Panamanian Law, with the purpose of hiding or covering their illicit origin to assist evasion of juridical consequences of such punishable acts shall be sanctioned with prison from 5 to 12 years and 100 to 200 days of fine.” Law 1 of 2004 added intellectual property violations as a predicate within Article 389 of the Penal Code. Panama’s law takes the predicate list approach to the crime of money laundering.

Panama has ratified both the Vienna Convention and the Palermo Convention, The Vienna Convention, Article 3(1)(b)(i) is satisfied by the language of Penal Code Articles 389 and 390. However, Article 6(2)(b) of the Palermo Convention is not fully satisfied, in that the list of predicate offenses does not include a fully comprehensive range of offenses associated with organized criminal groups. Penal Code Article 389 does cover 11 felony predicate offenses, but does not include all of the FATF Recommendations noted in the
Glossary of Definitions. In order to comply with this list, there should be predicate offense of terrorist financing, participation in an organized criminal group and racketeering, sexual exploitation including of children, trafficking in stolen goods (as opposed to only vehicles), counterfeit currency, environmental crime, murder, the general act of smuggling, piracy, fraud, and insider trading/market manipulation. ML is considered to be an autonomous offense. It is not subordinated to the predicate offense, and can be independently charged. The crime of money laundering applies to an individual who has committed a predicate offense, provided that the person carries out one or more of the terms governing the legal provisions in Articles 389–393.

Penal Code Article 389 applies to the listed predicates established in Panamanian law. The authorities advised that the crime of money laundering extends to conduct of predicate offenses which occur in other countries, as well as in Panama, and that Panamanian law would apply in either circumstance. Articles 8 and 9 of the Penal Code provide legal support for this position. Article 8 provides that Panamanian law will apply to punishable acts committed outside the borders of Panama, where those laws relate to acts against the government of Panama, crimes against public health [such as drug offenses], crimes against the national economy and public administration, and the falsification of official documents or money destined for Panama. Article 9 also applies
Panamanian law to acts committed outside the country where the results of the crime are produced in Panama, or there are other various listed effects on Panama.

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IMF Liechtenstein Anti-Money Laundering & Terrorist Financing

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  • 8 pages



Key Findings

1. The financial sector in Liechtenstein provides primarily wealth-management services, including banking, trust, other fiduciary services, investment management, and life insurance-based products. There has been significant expansion recently in the non-banking areas, particularly investment undertakings and insurance. Approximately 90 percent of Liechtenstein’s financial services business is provided to nonresidents, many attracted to
Liechtenstein by the availability of discrete and flexible legal structures, strict bank secrecy, and favorable tax arrangements, within a stable and well-regulated environment.

2. By its nature, Liechtenstein’s financial sector business creates a particular money laundering risk in response to which the authorities and the financial sector firms have developed risk-based mitigating measures. Minimizing the risk of abuse of corporate vehicles and related financial services products presents an ongoing challenge, as does the identification of the natural persons who are the beneficial owners of the underlying assets or legal persons or arrangements. Therefore, Liechtenstein is vulnerable mainly in the layering phase of money laundering. No particular vulnerability to terrorist financing was identified.

3. Liechtenstein was listed by the FATF as part of its initial review of noncooperative
countries and territories in 2000 but was delisted in 2001. The authorities have made
significant progress since that time in moving towards compliance with the FATF
Recommendations, as noted in the AML/CFT assessment conducted by the IMF in 2002 as
part of the Offshore Financial Center (OFC) assessment program and as evidenced by the
subsequent major legislative amendments and institutional restructuring.

4. Both ML and FT are criminalized broadly (though not fully) in line with the
international standard. There is no criminal liability of corporate entities. The quality of its
analysis and output indicates that the financial intelligence unit (FIU) makes effective use of
the information it receives. However, the effectiveness of the suspicious activity reporting
system could be improved by addressing factors that may be currently suppressing the level
of reporting, including, for example, the requirement for automatic freezing of assets for five
days following filing.

5. The investigative powers available to the law enforcement authorities are
comprehensive enough to enable them to conduct serious investigations in an effective way.
However, the number of investigations resulting from the files forwarded by the FIU appears
low and there have been just two prosecutions for (autonomous) money laundering and no
convictions. Most of the cases in which Liechtenstein has been involved, including some
high-profile cases, have links to other jurisdictions and the Liechtenstein prosecutors
consider it more effective to refer the cases to those jurisdictions where the main criminal
activity is alleged to have taken place and then provide strong support to the resultant
prosecution. There have been consequent convictions for money laundering or a predicate
offense, though not in Liechtenstein.

6. The AML/CFT law (Due Diligence Act–DDA) was last amended in February 2006
and is elaborated by a 2005 Due Diligence Ordinance (DDO) to provide the main legal basis
for the AML/CFT preventive measures. Banks and other financial institutions and relevant
DNFBPs are supervised by the Financial Market Authority (FMA), which reports directly to Parliament. However, some doubt remains as to whether the scope of AML/CFT coverage is sufficiently wide to fully meet the FATF Recommendations. The DDA and DDO provide a
broad framework for customer due diligence (CDD), though their provisions fall short of the
international standard on some substantive issues and a range of technical points. This
reflects the fact that, as in many European Economic Area (EEA) member states,
Liechtenstein plans to implement the EU Third Money Laundering Directive by 2008, during
which process the authorities will have an opportunity to address the identified deficiencies.

7. In Liechtenstein, CDD is based mainly on the obligation to prepare and maintain a
customer profile, including beneficial ownership information, source of funds, and purpose
of the relationship. Discussions with auditors, who are contracted by the FMA to conduct
most of the AML/CFT on-site supervision, indicate that levels of compliance have improved
significantly, although not evenly across all categories of reporting institutions. In identifying
high-risk customers and beneficial owners, excessive discretion is provided in the law to
financial institutions and there is no explicit requirement for enhanced due diligence. Having
regard to the inherent risk in much of the financial service business in Liechtenstein, there is
a need for additional attention to the quality and depth of the identification of beneficial
owners and the conduct of ongoing due diligence.

Preventive Measures—Financial Institutions

17. AML/CFT preventive measures are defined in the Due Diligence Act, the
requirements of which are expanded in secondary legislation in the Due Diligence Ordinance
(DDO). The DDA was significantly revised in 2004 with the aim of transposing the revised
FATF Recommendations, as well as the EC Directive 2001/97/EC. The DDA provides for
due diligence to be completed by legal and natural persons (personal scope) when conducting
financial transactions on a professional basis (substantive scope). All financial institutions
fall under the personal scope of application and, in practice, all FATF-defined transactions
are covered under the substantive scope of application.

18. Liechtenstein has established an overall risk-based approach which requires financial
institutions to build, and keep updated a profile for each long-term customer. The profile,
which is to be completed on a risk-sensitive basis, consolidates CDD data and includes
notably beneficial ownership information, source of funds, and purpose of the relationship.
Detection of suspicious activities is based on deviation from the profile on the basis of risk
criteria. However, by comparison with the FATF Recommendations, the legal provisions
may give excessive discretion to financial institutions when applying the risk-based system
and do not fully comply with a number of specific criteria of the standard. The DDA and the
DDO provide only broad instructions with regard to determining high-risk criteria for
customers, for all complex, unusual large transactions or unusual patterns of transaction, and
for transactions from countries that do not or inadequately apply the FATF
Recommendations, as well as to defining specific due diligence for PEPs or respondent
banks. Legal or regulatory requirements do not fully address the misuse of new technologies.
Identification, transaction and investigation records, which have to be maintained in
Liechtenstein for at least 10 years, should also be sufficient to permit reconstruction of
individual transactions and provide evidence for prosecution. Requirements for foreign
branches and subsidiaries related to AML/CFT need to be strengthened, particularly as
several of the Liechtenstein banks continue to expand their activities in other jurisdictions.

19. Provisions regarding CDD are broadly in line with the international standard, but,
whether conducted directly or through intermediaries, they need to be strengthened further in
some areas. The DDA and the DDO grant some exemptions to identification, and the
requirements for identification of beneficial owners, as well as verification of customers’ and
beneficial owners’ identity, need to be broadened. Financial institutions also may rely on
domestic and foreign intermediaries that introduce new business to provide them with
customer profile information and certified copies of identification documents, but also to
conduct ongoing monitoring of customers and transactions. Moreover, financial institutions
are legally protected (subject to certain conditions) from responsibility for deficiencies in
CDD conducted by their intermediaries.