___________________________________________________
US State Dept Narcotics Report 2012 (introduction):
Bosnia is not a major narcotics cultivator nor a significant narcotics
producer, consumer, or producer of precursor chemicals. Bosnia is still
considered primarily a transit country for drug trafficking due to its
strategic location along historic Balkan smuggling routes and its strategic
position between drug production and processing centers in Southwest
Asia and markets in Western Europe. Bosnian authorities at the state,
entity, cantonal, and municipal levels require further capacity to combat
the transit of illegal migrants, black market commodities, and narcotics,
but state-level institutions have improved their ability to stop the flow of
illicit narcotics in the country. Bosnia is a party to the 1988 UN Drug
Convention, the UN Convention against Corruption and the UN
Convention against Transnational Organized Crime. A 1902 extradition
treaty between the U.S. and the Kingdom of Serbia applies to Bosnia
and Herzegovina as a successor state.
Weak state institutions, lack of personnel in counternarcotics units, and
imperfect cooperation among the responsible authorities also contribute
to Bosnia’s vulnerability to narcotics trafficking. Cooperation among law
enforcement agencies and prosecutors is primarily informal and ad hoc,
and serious legal and bureaucratic obstacles exist to the effective
prosecution of criminals remain. The political will to improve narcotics
control performance exists in many quarters of the Bosnian government,
at the state, entity and district levels. However, faced with competing
demands, the government has focused its limited law enforcement
resources more on such problems as investigating and prosecuting war
crimes, counterterrorism, and combating trafficking in persons. It has not
developed comprehensive antinarcotics intelligence and enforcement
capabilities.
Bosnia has a state-level counternarcotics coordination body and a
commission for the destruction of illegal narcotics. The counternarcotics
coordination body adopted a counter-narcotics strategy and action plan.
Bosnia has limited financial resources, but with USG and EU assistance,
it is attempting to improve its ability to combat narcotics trafficking and
organized crime and to achieve compliance with relevant international
conventions. Bosnia has increased its cooperation with regional and
international law enforcement agencies. The Border Police (BP), the
Indirect Taxation Authority (the Bosnian customs service), and the State
Investigative and Protection Agency (SIPA) have improved
counternarcotics efforts, but continued underfunding, lack of staffing,
and an ill-equipped BP and SIPA remain a challenge. Telephone
hotlines, local press coverage, and public relations efforts have focused
public attention on smuggling and black-marketeering, encouraging an
enforcement response and improvements.
As a matter of government policy, Bosnia does not encourage or
facilitate illicit production or distribution of narcotic or psychotropic drugs
or other controlled substances, or the laundering of proceeds from
illegal drug transactions.
The BP is responsible for controlling the country's three international
airports, as well as Bosnia's 55 international border crossings covering
1,551 kilometers. The BP has been considered one of the more effective
border services in Southeast Europe and is one of the best functioning
multi-ethnic state-level institutions in Bosnia. However, there are
sustained personnel shortages in the BP. There are still a large number
of illegal crossing points, including rural roads and river fords, which the
BP lacks capacity to patrol. In-ground sensors have been deployed to
close some of these gaps, but response times to sensor alerts are also
affected by lack of equipment such as vehicles. Moreover, many official
checkpoints and crossings remain understaffed. SIPA is supposed to be
a conduit for information and evidence between local, state, and
international law enforcement agencies. However, cooperation between
local law enforcement agencies and SIPA is often less than optimal.
Despite structural challenges, law enforcement agencies, often in
cooperation with neighboring countries, have succeeded in making
narcotic-related arrests and seizures. Through September 2011 (latest
available statistics), law enforcement agencies in Bosnia and
Herzegovina (including the State Investigation and Protection Agency,
the Border Police, Federation Ministry of Interior, Republika Srpska
Ministry of Interior, and Brcko District Police) report having seized 1.3 kg
of heroin, 26 g of cocaine, 113.5 kg of marijuana, 2,298 cannabis plants,
and 3,357 cannabis seeds.
While most drugs entering Bosnia are being trafficked to other
destinations, primarily to Western Europe, indigenous or regional
organized crime groups are engaged in the local distribution of narcotics
to the estimated 105,000 drug users in the country. There is evidence of
links and conflict among Bosnian criminal elements and organized crime
operations in Russia, Albania, Serbia, Montenegro, Croatia, Austria,
Germany, Italy, and increasingly from South America. Organized crime,
working with a few corrupt government officials according to anecdotal
evidence, uses the narcotics trade to generate revenue. There is no
credible evidence linking senior government officials to the illicit
narcotics trade.
Strengthening state-level law enforcement and judicial institutions,
promoting the rule of law, combating organized crime and terrorism, and
reforming the judiciary and police in Bosnia remain top USG priorities.
The USG will continue to focus its bilateral program on related subjects
such as public sector corruption and improved border controls. The USG
will continue to work closely with Bosnian authorities and the
international community to encourage Bosnia to proceed with the full
implementation of its national counternarcotics strategy. Bosnia
recognizes the 1902 extradition treaty between the U.S. and the
Kingdom of Serbia; the level of cooperation between the parties is good
even in the absence of a formal mutual legal assistance treaty.
For Full report, click here
_________________________________________________________
US State Dept Trafficking in Persons Report 2011 (introduction):
(Tier 1)
Bosnia and Herzegovina is a source, destination and transit country for
men, women and children who are subjected to sex trafficking and forced
labor. Bosnian victims are subjected to sex trafficking and forced labor in
Azerbaijan, Slovenia, Croatia and other countries in Europe. Women
from Albania, Serbia, Kosovo, and Bosnian women and young girls were
subjected to sex trafficking within the country. Local girls, particularly
Roma, were trafficked, using forced marriage, for the purpose of
domestic servitude. Roma boys and girls, some as young as 4 years old,
were subjected to forced begging by organized crime groups. An NGO
reported children as young as 12 years old are subjected to sex
trafficking by traffickers who use blackmail, gang rape, and drugs as
tools of coercion and control.
The Government of Bosnia fully complies with the minimum standards for
the elimination of trafficking. The government demonstrated sustained
law enforcement and victim protection efforts, and set a leading example
in a forced begging case in 2010. However, it did not proactively identify
trafficking victims, likely resulting in their punishment for unlawful acts
committed as a result of being trafficked. Some NGOs reported that
trafficking-related corruption significantly hampered the government’s
ability to vigorously prosecute trafficking and to identify and protect
victims.
For full report click here
________________________________________________________
US State Dept Terrorism Report 2010
Overview: Bosnia and Herzegovina made progress increasing its
counterterrorism capacity in 2010 and improved its interagency
communication and cooperation between the various state and entity-
level law enforcement agencies. Joint operations were conducted
against suspected terrorist groups, the State Court prosecuted
perpetrators of acts of terrorism, and Bosnia revamped its
Counterterrorism Task Force to better counter potential terrorist threats.
2010 Terrorist Incidents: On June 27, a bomb was detonated at a police
headquarters in the central Bosnian town of Bugojno resulting in the
death of one police officer and injuries to six other officers. The State
Prosecutor indicted six suspects on terrorism charges for their roles in
the attack. The suspects reportedly belonged to a local violent extremist
movement.
Legislation and Law Enforcement: In order to harmonize Bosnia and
Herzegovina’s criminal code with UN and EU standards related to
countering terrorism, the parliament adopted new legislation in January
to criminalize terrorist recruitment, terrorist training, and the incitement of
terrorist attacks.
The trial against Rijad Rustempasic and three other defendants on
terrorism and weapons trafficking charges commenced in February. In
early February, in an extensively coordinated effort involving several
different law enforcement institutions and police forces, approximately
600 police and law enforcement officers conducted a raid on the village
of Gornja Maoca, where authorities suspected the local religious
extremist movement of involvement in criminal activity. A significant
amount of evidence was seized during the raid and the suspects
remained under investigation by law enforcement authorities at year’s
end.
In December, the State Prosecutor’s Office and State Investigative and
Protective Agency (SIPA) began discussions on forming an operational
Joint Task Force based on the FBI model to deal with counterterrorism.
The Ministry of Security will fund the Joint Task Force and it will operate
out of SIPA. The Ministry of Security recently adopted a strategy to
prevent and counter terrorism covering the period of 2010-2013.
Countering Terrorist Finance: In August, the Directors of the Federation
and Republika Srpska Tax Administrations and SIPA agreed to form an
operations team to evaluate financial information of persons and groups
of interest to counter terrorist financing. This initiative will assist the Joint
Task Force’s focus on the financing of terrorism-related activity.
Regional and International Cooperation: Bosnia and Herzegovina’s law
enforcement agencies regularly interact with their U.S. and European
counterparts on counterterrorism investigations. Bosnia ratified the
Amendment to the Convention on the Physical Protection of Nuclear
Material.
Countering Radicalization and Violent Extremism: In December in
Sarajevo, the Ministry of Security co-sponsored the OSCE’s workshop on
Suppressing Terrorist Financing and Countering Violent Extremism and
Radicalization that Leads to Terrorism. The OSCE sponsored-event
brought together representatives from the NGO-sector, banking
industry, and representatives from 15 countries and regional
organizations.
_________________________________________________________
Links:
Worldwide AML Legislation (International Bar Association)
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|
Sanctions:
Bosnia & Herzegovina is regarded as being part of the
geographical region of the Western Balkans and therefore falls
under the US sanction order as follows: -
http://www.treasury.gov/resource-
center/sanctions/Programs/pages/balkans.aspx
The European Union adopted Council Regulation (EC) No
1295/98 on 22 June 1998. The Regulation provided, among other
matters, for a freeze on the funds of the Governments of the
Federal Republic of Yugoslavia (FRY) and the Republic of Serbia.
The restrictive measures were subsequently modified to include a
ban on investment in the FRY and the Republic of Serbia.
Council Regulation (EC) No 2488/2000 lifted the investment ban
and the financial sanctions in respect of the FRY and the Republic
of Serbia. However, specific sanctions still applied to former
President Slobodan Milosevic and those persons associated with
him.
Commission Regulation (EC) No 1205/2001 modified the financial
sanctions to cover only those funds belonging to Mr Slobodan
Milosevic, and certain members of his family and other close
associates. The Regulation had the effect of amending the list of
persons in Annex I of Council Regulation (EC) No 2488/2000 to
whom the financial sanctions apply.
For further information:
http://www.hm-treasury.gov.uk/fin_sanctions_yugoslavia.htm
http://ec.europa.
eu/external_relations/cfsp/sanctions/docs/measures_en.pdf
____________________________________________________
Offshore Jurisdiction Blacklists – Further Information:
Information unavailable.
____________________________________________________
US State Department Money Laundering Report - 2011:
Bosnia and Herzegovina (BiH) is a primarily cash-based economy
and is not an international or regional financial center. Most
money laundering activities in BiH are for purposes of evading
taxes. A lesser portion involves concealing the proceeds of illegal
activity such as trafficking, drugs, and corruption. BiH authorities
have had some success in clamping down on money laundering in
the formal banking system. However, with porous borders and
weak enforcement capabilities, BiH is a significant market and
transit point for smuggled commodities including cigarettes,
narcotics, firearms, counterfeit goods, lumber, and fuel oils. The
cash-based economy and weak border controls on bulk cash
couriers also contribute to making BiH an attractive venue for
organized criminal elements and potential terrorist financiers.
There is no indication law enforcement has taken action to
combat the trade-based money laundering likely to be occurring
in BiH. Corruption is endemic, affecting all levels of the economy
and society.
There are four active free trade zones in BiH, with production
based mainly on automobiles and textiles. There have been no
reports that these areas are used in trade-based money
laundering. The Ministry of Foreign Trade and Economic
Relations is responsible for monitoring free trade zone activities.
DO FINANCIAL INSTITUTIONS ENGAGE IN CURRENCY
TRANSACTIONS RELATED TO INTERNATIONAL NARCOTICS
TRAFFICKING THAT INCLUDE SIGNIFICANT AMOUNTS OF US
CURRENCY; CURRENCY DERIVED FROM ILLEGAL SALES IN
THE U.S.; OR THAT OTHERWISE SIGNIFICANTLY AFFECT THE
U.S.: NO
CRIMINALIZATION OF MONEY LAUNDERING:
“All serious crimes” approach or “list” approach to predicate
crimes: All serious crimes
Legal persons covered: criminally: YES civilly: NO
CRIMINALIZATION OF TERRORIST FINANCING:
Ability to freeze terrorist assets without delay: YES
UN lists of designated terrorists or terrorist entities distributed to
financial institutions: YES
(Please refer to the Department of State’s Country Reports on
Terrorism, which can be found here: http://www.state.
gov/s/ct/rls/crt/)
KNOW-YOUR-CUSTOMER RULES:
Covered entities: Banks and currency exchange offices; financial
leasing firms; insurance companies; post offices; investment and
mutual pension companies; stock exchanges and stock exchange
agencies; casinos and gaming enterprises; dealers in vehicles,
art, precious metals and stones; lawyers, notaries, auditors, and
accountants; real estate brokers; company formation agents, trust
and asset managers; pawnshops; travel agents; auctioneers; and
charities
Enhanced due diligence procedures for PEPs: Foreign: YES
Domestic: NO
SUSPICIOUS TRANSACTION REPORTING REQUIREMENTS:
Covered entities: Banks and currency exchange offices; financial
leasing firms; individuals; post offices, investment and mutual
pension companies, stock exchanges and stock exchange
agencies, insurance companies, casinos and gaming enterprises;
dealers in vehicles, art, precious metals and stones; lawyers,
notaries, auditors, and accountants; real estate brokers; company
formation agents, trust and asset managers; pawnshops; travel
agents; auctioneers; and charities
Number of STRs received and time frame: None in 2010
Number of CTRs received and time frame: 227,077 in 2010
MONEY LAUNDERING CRIMINAL
PROSECUTIONS/CONVICTIONS:
Prosecutions: Three against seven persons and four legal entities
in 2010
Convictions: 13 - 2009 – 2010; one was overturned on appeal
Assets forfeited: criminally: approximately $225,000 civilly: Not
applicable
RECORDS EXCHANGE MECHANISM:
With U.S.: YES
With other governments/jurisdictions: YES
BiH is a member of Moneyval, a Financial Action Task Force
(FATF)-style regional body. Its most recent mutual evaluation can
be found here: www.coe.
int/t/dghl/monitoring/moneyval/Countries/BH_en.asp
ENFORCEMENT AND IMPLEMENTATION ISSUES AND
COMMENTS:
BiH’s political structure and ethnic politics hinder its anti-money
laundering/counter-terrorist financing (AML/CFT) regime.
Coordination of financial law enforcement among the multiple
jurisdictional levels in BiH -- the State, the two entities (the
Federation of Bosnia and Herzegovina and the Republika
Srpska), and Brcko District – is improving. The jurisdictions
maintain separate financial supervision and enforcement bodies.
The State, the two entities, and Brcko District should move quickly
to prepare and adopt a national action plan or strategy to address
the AML/CFT deficiencies. Although State-level institutions are
becoming more firmly grounded and are gaining increased
authority, overlapping responsibilities regarding investigation of
money laundering and terrorist financing cause confusion and
impede efforts to improve operational capabilities.
BiH law enforcement and customs authorities should take
additional steps to control the integrity of the borders and limit
smuggling. BiH law requires customs officials and the Indirect Tax
Administration (ITA) to report to the financial intelligence unit (FIU)
all cross-border transportation of cash and securities in excess of
KM 10,000 (approximately $6,800). However, due to confusing
and possibly conflicting laws at the state and entity levels, weak
enforcement and corruption, large amounts of currency leave and
enter the country undetected. In addition, the ITA has no authority
to seize currency from the carrier upon discovery of a false
declaration or suspicion of illegal activity. Although the
Government of BiH recognizes the threat of money laundering
posed by bulk cash couriers, it has been unable to manage the
problem.
In practice, most of the institutions subject to the STR
requirements, other than commercial banks, have not received
guidance and, consequently, do not understand their obligations
or comply with the law. Neither the securities sector nor the
insurance sector has submitted any STRs recently. Officially, the
FIU has access to other Government entities’ records, and formal
mechanisms for interagency information-sharing are in place. In
practice, however, the FIU has only limited access to the full range
of databases required to perform proper analysis, and
cooperation between the FIU and other Government agencies –
particularly the different police forces -- is weak, with little
information shared among agencies. Since June 2010, following
the installation of a new department head, the level of cooperation
with the agencies has improved and information has been shared
in both directions.
The Government of BiH should continue to strengthen institutions
with responsibilities for money laundering prevention, particularly
those at the State level. Due to a lack of resources and
bureaucratic politics, the FIU, like many State institutions, remains
under-funded and under-resourced. The Government of BiH
should amend its Law on Money Laundering and Terrorist
Financing to clarify the FIU’s obligation to disseminate information
outside the organization and increase independence of the
organization. Although prosecutors, financial investigators, and
tax administrators have received training on tax evasion, money
laundering, and other financial crimes, BiH should enhance the
capacity to understand diverse methodologies, and aggressively
pursue investigations. BiH authorities should undertake efforts to
understand the illicit markets and their role in trade-based money
laundering and alternative remittance systems.
BiH should take specific steps to completely implement its anti-
corruption strategy and to combat corruption at all levels of
commerce and government. The government should enact
implementing legislation for the international conventions to which
it is a party.
BiH and all entities have laws which address asset forfeiture.
However, the Republika Srpska is the only entity with specific
legislation addressing the management of property obtained
through asset forfeiture. BiH authorities rarely use these forfeiture
provisions and their interpretation is subject to great debate. BiH
should adopt a comprehensive asset forfeiture law that provides a
formal mechanism for the administration of seized assets.
Bosnia & Herzegovina is regarded as being part of the
geographical region of the Western Balkans and therefore falls
under the US sanction order as follows: -
http://www.treasury.gov/resource-
center/sanctions/Programs/pages/balkans.aspx
The European Union adopted Council Regulation (EC) No
1295/98 on 22 June 1998. The Regulation provided, among other
matters, for a freeze on the funds of the Governments of the
Federal Republic of Yugoslavia (FRY) and the Republic of Serbia.
The restrictive measures were subsequently modified to include a
ban on investment in the FRY and the Republic of Serbia.
Council Regulation (EC) No 2488/2000 lifted the investment ban
and the financial sanctions in respect of the FRY and the Republic
of Serbia. However, specific sanctions still applied to former
President Slobodan Milosevic and those persons associated with
him.
Commission Regulation (EC) No 1205/2001 modified the financial
sanctions to cover only those funds belonging to Mr Slobodan
Milosevic, and certain members of his family and other close
associates. The Regulation had the effect of amending the list of
persons in Annex I of Council Regulation (EC) No 2488/2000 to
whom the financial sanctions apply.
For further information:
http://www.hm-treasury.gov.uk/fin_sanctions_yugoslavia.htm
http://ec.europa.
eu/external_relations/cfsp/sanctions/docs/measures_en.pdf
____________________________________________________
Offshore Jurisdiction Blacklists – Further Information:
Information unavailable.
____________________________________________________
US State Department Money Laundering Report - 2011:
Bosnia and Herzegovina (BiH) is a primarily cash-based economy
and is not an international or regional financial center. Most
money laundering activities in BiH are for purposes of evading
taxes. A lesser portion involves concealing the proceeds of illegal
activity such as trafficking, drugs, and corruption. BiH authorities
have had some success in clamping down on money laundering in
the formal banking system. However, with porous borders and
weak enforcement capabilities, BiH is a significant market and
transit point for smuggled commodities including cigarettes,
narcotics, firearms, counterfeit goods, lumber, and fuel oils. The
cash-based economy and weak border controls on bulk cash
couriers also contribute to making BiH an attractive venue for
organized criminal elements and potential terrorist financiers.
There is no indication law enforcement has taken action to
combat the trade-based money laundering likely to be occurring
in BiH. Corruption is endemic, affecting all levels of the economy
and society.
There are four active free trade zones in BiH, with production
based mainly on automobiles and textiles. There have been no
reports that these areas are used in trade-based money
laundering. The Ministry of Foreign Trade and Economic
Relations is responsible for monitoring free trade zone activities.
DO FINANCIAL INSTITUTIONS ENGAGE IN CURRENCY
TRANSACTIONS RELATED TO INTERNATIONAL NARCOTICS
TRAFFICKING THAT INCLUDE SIGNIFICANT AMOUNTS OF US
CURRENCY; CURRENCY DERIVED FROM ILLEGAL SALES IN
THE U.S.; OR THAT OTHERWISE SIGNIFICANTLY AFFECT THE
U.S.: NO
CRIMINALIZATION OF MONEY LAUNDERING:
“All serious crimes” approach or “list” approach to predicate
crimes: All serious crimes
Legal persons covered: criminally: YES civilly: NO
CRIMINALIZATION OF TERRORIST FINANCING:
Ability to freeze terrorist assets without delay: YES
UN lists of designated terrorists or terrorist entities distributed to
financial institutions: YES
(Please refer to the Department of State’s Country Reports on
Terrorism, which can be found here: http://www.state.
gov/s/ct/rls/crt/)
KNOW-YOUR-CUSTOMER RULES:
Covered entities: Banks and currency exchange offices; financial
leasing firms; insurance companies; post offices; investment and
mutual pension companies; stock exchanges and stock exchange
agencies; casinos and gaming enterprises; dealers in vehicles,
art, precious metals and stones; lawyers, notaries, auditors, and
accountants; real estate brokers; company formation agents, trust
and asset managers; pawnshops; travel agents; auctioneers; and
charities
Enhanced due diligence procedures for PEPs: Foreign: YES
Domestic: NO
SUSPICIOUS TRANSACTION REPORTING REQUIREMENTS:
Covered entities: Banks and currency exchange offices; financial
leasing firms; individuals; post offices, investment and mutual
pension companies, stock exchanges and stock exchange
agencies, insurance companies, casinos and gaming enterprises;
dealers in vehicles, art, precious metals and stones; lawyers,
notaries, auditors, and accountants; real estate brokers; company
formation agents, trust and asset managers; pawnshops; travel
agents; auctioneers; and charities
Number of STRs received and time frame: None in 2010
Number of CTRs received and time frame: 227,077 in 2010
MONEY LAUNDERING CRIMINAL
PROSECUTIONS/CONVICTIONS:
Prosecutions: Three against seven persons and four legal entities
in 2010
Convictions: 13 - 2009 – 2010; one was overturned on appeal
Assets forfeited: criminally: approximately $225,000 civilly: Not
applicable
RECORDS EXCHANGE MECHANISM:
With U.S.: YES
With other governments/jurisdictions: YES
BiH is a member of Moneyval, a Financial Action Task Force
(FATF)-style regional body. Its most recent mutual evaluation can
be found here: www.coe.
int/t/dghl/monitoring/moneyval/Countries/BH_en.asp
ENFORCEMENT AND IMPLEMENTATION ISSUES AND
COMMENTS:
BiH’s political structure and ethnic politics hinder its anti-money
laundering/counter-terrorist financing (AML/CFT) regime.
Coordination of financial law enforcement among the multiple
jurisdictional levels in BiH -- the State, the two entities (the
Federation of Bosnia and Herzegovina and the Republika
Srpska), and Brcko District – is improving. The jurisdictions
maintain separate financial supervision and enforcement bodies.
The State, the two entities, and Brcko District should move quickly
to prepare and adopt a national action plan or strategy to address
the AML/CFT deficiencies. Although State-level institutions are
becoming more firmly grounded and are gaining increased
authority, overlapping responsibilities regarding investigation of
money laundering and terrorist financing cause confusion and
impede efforts to improve operational capabilities.
BiH law enforcement and customs authorities should take
additional steps to control the integrity of the borders and limit
smuggling. BiH law requires customs officials and the Indirect Tax
Administration (ITA) to report to the financial intelligence unit (FIU)
all cross-border transportation of cash and securities in excess of
KM 10,000 (approximately $6,800). However, due to confusing
and possibly conflicting laws at the state and entity levels, weak
enforcement and corruption, large amounts of currency leave and
enter the country undetected. In addition, the ITA has no authority
to seize currency from the carrier upon discovery of a false
declaration or suspicion of illegal activity. Although the
Government of BiH recognizes the threat of money laundering
posed by bulk cash couriers, it has been unable to manage the
problem.
In practice, most of the institutions subject to the STR
requirements, other than commercial banks, have not received
guidance and, consequently, do not understand their obligations
or comply with the law. Neither the securities sector nor the
insurance sector has submitted any STRs recently. Officially, the
FIU has access to other Government entities’ records, and formal
mechanisms for interagency information-sharing are in place. In
practice, however, the FIU has only limited access to the full range
of databases required to perform proper analysis, and
cooperation between the FIU and other Government agencies –
particularly the different police forces -- is weak, with little
information shared among agencies. Since June 2010, following
the installation of a new department head, the level of cooperation
with the agencies has improved and information has been shared
in both directions.
The Government of BiH should continue to strengthen institutions
with responsibilities for money laundering prevention, particularly
those at the State level. Due to a lack of resources and
bureaucratic politics, the FIU, like many State institutions, remains
under-funded and under-resourced. The Government of BiH
should amend its Law on Money Laundering and Terrorist
Financing to clarify the FIU’s obligation to disseminate information
outside the organization and increase independence of the
organization. Although prosecutors, financial investigators, and
tax administrators have received training on tax evasion, money
laundering, and other financial crimes, BiH should enhance the
capacity to understand diverse methodologies, and aggressively
pursue investigations. BiH authorities should undertake efforts to
understand the illicit markets and their role in trade-based money
laundering and alternative remittance systems.
BiH should take specific steps to completely implement its anti-
corruption strategy and to combat corruption at all levels of
commerce and government. The government should enact
implementing legislation for the international conventions to which
it is a party.
BiH and all entities have laws which address asset forfeiture.
However, the Republika Srpska is the only entity with specific
legislation addressing the management of property obtained
through asset forfeiture. BiH authorities rarely use these forfeiture
provisions and their interpretation is subject to great debate. BiH
should adopt a comprehensive asset forfeiture law that provides a
formal mechanism for the administration of seized assets.
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| Further Tables |
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*Please note that FATF deems that a country has significant aml deficiencies if any
of the 'Core' Recommendations, R1, R5, R10, R13, SRII, or SRIV are rated either
Partially of Non-Compliant. These are marked in red.
For FATF to remove a country from the regular follow-up process, it has to be rated
Compliant or Largely Compliant in the above mentioned Core Recommendations
and the following Key Recommendations: -
R3, R4, R23, R26, R35, R36, R40, SRI, SRIII, SRV
Please also note that any risk assessment should take into consideration all
follow-up reports.
of the 'Core' Recommendations, R1, R5, R10, R13, SRII, or SRIV are rated either
Partially of Non-Compliant. These are marked in red.
For FATF to remove a country from the regular follow-up process, it has to be rated
Compliant or Largely Compliant in the above mentioned Core Recommendations
and the following Key Recommendations: -
R3, R4, R23, R26, R35, R36, R40, SRI, SRIII, SRV
Please also note that any risk assessment should take into consideration all
follow-up reports.
| BOSNIA & HERZEGOVINA |
| KnowYourCountry |
|
|
| Last Updated: 16 April 2012 |