Higher Risk
 
Medium Risk
 
Info n/a
 
Lower Risk
Bilateral exchange of information
Agreements in place?
    No
Sanctions:

Croatia 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://eeas.europa.eu/cfsp/sanctions/docs/measures_en.pdf

____________________________________________________

Offshore Jurisdiction Blacklists – Further Information:

Information unavailable.

____________________________________________________

US State Department Money Laundering Report  -  2011:

Croatia is not considered an off-shore financial center. Croatian
authorities consider most money laundering in the country to be
of domestic origin, involving the proceeds of illegal domestic
narcotics sales and economic crimes, such as fraud and tax
evasion. Although Croatia is part of a major transit route for drugs
entering Europe, there is little evidence that these networks have
utilized Croatia’s financial systems. Public corruption has been
linked to money laundering, but no proof of the association exists.
Alleged money laundering connected to public corruption has not,
however, been linked to terrorist financing. Money laundering in
Croatia occurs primarily through non-resident accounts, transfers
to off-shore banks using counterfeit documents, and deposits on
foreign currency accounts, and has often been linked to the real
estate market and the purchase of high-end automobiles.

Croatia does not represent a sizeable market for smuggled
goods, but is used as a transit route for goods destined for other
countries in the region. There is not a significant black market in
Croatia. There is no indication that trade-based money laundering
exists in Croatia.

Croatia has 15 free trade zones, 13 of which are presently in
operation. Companies operating in the zones benefit from lower
taxes and customs and value-added free import of input materials.
Companies operating in free trade zones are subject to the same
regulation and supervision as all other businesses in the country.

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: YES

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

KNOW-YOUR-CUSTOMER RULES:

Covered entities: Banks, finance companies, and financial leasing
entities; savings banks; credit unions; companies performing
payment option services; the Croatian Post Office; investment
fund managers, guarantors, and asset managers; pension
companies; insurance companies and intermediaries; companies
dealing with the issuance of electronic money; authorized
exchange offices; gaming-related providers; pawnshops,
auctioneers, and traders of precious metals and gems, fine arts,
and antiquities; lawyers, notaries public, auditors, accountants
and tax advisors

Enhanced due diligence procedures for PEPs: Foreign: YES
Domestic: YES

SUSPICIOUS TRANSACTION REPORTING REQUIREMENTS:

Covered entities: Banks, finance companies, and financial leasing
entities; savings banks; credit unions; companies performing
payment option services; the Croatian Post Office; investment
fund managers, guarantors, and asset managers; pension
companies; insurance companies and intermediaries; companies
dealing with the issuance of electronic money; authorized
exchange offices; gaming-related providers; pawnshops,
auctioneers, and traders of precious metals and gems, fine arts,
and antiquities; lawyers, notaries public, auditors, accountants
and tax advisors

Number of STRs received and time frame: 404 in 2010

Number of CTRs received and time frame: 57,648 in 2010

MONEY LAUNDERING CRIMINAL
PROSECUTIONS/CONVICTIONS:

Prosecutions: 11 – January - June 2010

Convictions: Five – January - June 2010

Assets forfeited: criminally: Not available civilly: Not available

RECORDS EXCHANGE MECHANISM:

With U.S.: YES

With other governments/jurisdictions: YES

Croatia is a member of the Council of Europe’s Select Committee
of Experts (MONEYVAL), a Financial Action Task Force (FATF)-
style regional body. Its most recent mutual evaluation can be
found here: http://www.coe.
int/t/dghl/monitoring/moneyval/Countries/Croatia_en.asp

ENFORCEMENT AND IMPLEMENTATION ISSUES AND
COMMENTS:

Croatia is a signatory to bilateral agreements with 32 FIU
counterparts and is also party to a number of bilateral
agreements on law enforcement cooperation with its neighbors.
The country actively cooperates with its Balkan neighbors in the
law enforcement arena, especially in the fight against money
laundering. Croatia worked to establish a regional working group
to address money laundering.

The FIU has the authority to freeze assets and can do so with
relatively little difficulty for an initial 72-hour period. Obtaining an
extension is slightly more complicated, with the Prosecutor’s Office
requiring either an international instrument or a formal legal
request for an extended asset freeze. Therefore, if assets
identified by authorities do not relate to an individual or entity
cited by the UN, it is more difficult for the Prosecutor’s Office to
obtain a long-term freeze. According to a FIU representative,
every request to extend an asset freeze has been granted by
court order and remained in effect through the end of the
proceedings. Croatia should ensure it has all the legal and
regulatory measures in place to meet the international standards
on national asset freezing mechanisms.

The Government of Croatia has sufficient mechanisms in place
and tools at its disposal to effectively combat money laundering
and financial crimes, and incidences of these activities remain
rare. A lack of expertise in financial crimes matters among the
police and judiciary stands in the way of an even more efficient
system, but attempts at education in this area have proved
helpful. As a candidate for EU accession, Croatia’s ability to
successfully combat money laundering and financial crimes is
under scrutiny, which has and should continue to lead to further
efforts to better develop its capacities in this area.

____________________________________________________

US State Dept Narcotics Report 2012 (introduction):

The Republic of Croatia is a transit point through which narcotics
are smuggled from production countries to consumer countries.
Croatia has a strong legal and institutional framework to control
and suppress narcotics related crimes. All available indicators
suggested that heroin availability was down on the domestic
market, part of a pan-European trend. Nevertheless, heroin
smuggling over the “Balkan route” as well as maritime cocaine
trafficked through seaports remain formidable challenges. Croatia
is primarily a transit country for cannabis, with its negligible
production primarily for personal use or domestic sale. The
central precepts of Croatia’s drug policy have remained consistent
throughout 2010 and 2011 as the country continued to implement
its 2006-2012 National Strategy on Combating Narcotic Drugs
Abuse and the 2009-2012 Action Plan on Combating Narcotic
Drugs Abuse.

Croatia is a party to the 1988 UN Drug Convention. Croatia is also
a party to the UN Convention against Corruption and the UN
Convention against Transnational Organized Crime and its three
protocols. Extradition between Croatia and the United States is
governed by the 1902 Extradition Treaty between the United
States and the Kingdom of Serbia, which applies to Croatia as a
successor state. Under the latter agreement, Croatia is not
obligated to extradite its nationals. Croatia has provided mutual
legal assistance in a narcotics investigation based on reciprocity.

Croatian laws are generally sufficient to combat narcotics
trafficking and drug use. Per the Act on Combating Drugs Abuse,
seized illicit drugs are destroyed in the presence of the Committee
for Destruction of Seized Illicit Drugs. Two planned drug
destructions occurred in 2010 (May and December) when almost
569 kg of illicit drugs and more than 1 ton of precursors were
destroyed. During 2010, mephedrone was added to the list of
drugs under legal control as a psychoactive substance inline with
EU standards.

The USG is not aware of any allegations of senior government or
other government officials participating in narcotics-related
corruption activities. Croatia is a party to the UN Convention
Against Corruption.

During 2010, 7,550 persons were treated for drug abuse, 6,175
(81.8%) of which were treated for opiate addiction, with 1,375
(18.2%) for an addiction to other psychotropic substances,
primarily cannabinoids (11.4%). Cocaine abuse is found among
1.6% of cases, a majority of which (60.4%) are repeat patients. Of
this overall group, 82.9% was male; a male to female ratio of
almost 5-1. In 2010, therapeutic communities offered treatment to
a total of 939 persons, 45.3% received treatment for the first time.
In therapeutic communities, opiate addicts made up (93.9%) of
those seeking care, with males making up (80.5%). Psychosocial
treatment included 2,020 families of drug addicts. There are
reportedly no drug treatment waiting lists or any cost for patients,
which Croatian doctors cite for low rates of hepatitis and HIV
infections.

In 2010, police reported 7,784 criminal offences for narcotic drugs
abuse (a 10.2% increase over 2009), accounting for 10.6% of all
crime in the Republic of Croatia. 5,423 persons were taken into
custody for the above-cited 7,784 offenses. This is an 8%
increase over last year when 5,019 were held. In 2010, there were
5,982 drug seizures, a 14% increase over the previous year,
reversing three consecutive years of reduced seizures. During
2010, the following narcotics were seized: 98kg-heroin, 15kg-
cocaine, 422kg-marijuana, 3.4kg-hashish, 7kg-amphetamine,
2,159-ecstasy tablets, 100-LSD doses and 3,448-methadone
tablets. During the first 6 months of 2011, the following seizures
occurred: 1.34kg-heroin, 1.263kg-cocaine, 117.75kg-marijuana,
455g- hashish, 1,112-cannabis plants, 16.75 kg-amphetamines,
1655-ecstasy tablets, 104-LSD doses, 2,639-methadone tablets.
Drug seizures increased 35% during the first six months in 2011
over the same period in 2010. Operating on Croatian supplied
intelligence the Brazilian federal police seized 180kg of cocaine
and discovered a hidden laboratory for cocaine production in
October 2010. In March 2011, Brazilian federal police seized
121.8 kg of cocaine and arrested 5 suspects based on
cooperation with the Croatian authorities. In April 2011, Croatian
cooperation with Austrian police resulted in the arrest of several
suspects and the seizure of 105kg of cocaine. In May 2011,
Croatian authorities cooperated with the Spanish police who
seized 368kg of cocaine and arrested several individuals.

Croatia has a well-developed institutional and legal framework to
suppress narcotics-related crime and to implement preventive and
educational programs. Treatment programs for drug abuse have
improved thanks to early detection, rehabilitation and social
reintegration of drug addicts as well as robust prosecution for illicit
activity. The Croatian police continued to partner with regional
neighbors as well as U.S. agencies and the EU. Joint operations
between the US Drug Enforcement Administration and the Interior
Ministry’s Drug Division occur regularly and Croatian authorities
are regular attendees at operational meetings and conferences in
the region. Croatia is a popular, mostly peaceful, family holiday
destination and the country is not known for drug-related tourism;
however, raves (fast-paced electronic music and light show mass
gatherings typically held in warehouses) can attract some ‘drug-
tourists.’

For Full report, click here

____________________________________________________

US State Dept Trafficking in Persons Report 2011
(introduction):

(Tier 1)

Croatia is a destination, source, and transit country for men,
women, and children subjected to conditions of sex trafficking and
forced labor. Croatian women and girls fall victim to sex trafficking
within the country, and women and girls from Serbia, Bosnia and
Herzegovina, and other parts of Eastern Europe are subjected to
sex trafficking in Croatia. Some Croatian women and girls are
subjected to sex trafficking in Western European countries.
Women and men reportedly have been subjected to forced labor
in agricultural sectors, and children, including Roma, are
subjected to forced begging, theft, labor, and sexual exploitation.

The Government of Croatia fully complies with the minimum
standards for the elimination of trafficking. During the reporting
period, the government sustained its anti-trafficking law
enforcement efforts, though it showed mixed efforts in victim
protection this year. Although the number of victims identified and
cared for increased during the reporting period, the funding to
care for those victims decreased. Of concern, the government
failed to identify children in prostitution as victims of trafficking,
instead prosecuting them for prostitution. The government’s
efforts on prevention, however, did improve; it focused research
and outreach efforts on understanding and combating labor
trafficking.

For full report click here

____________________________________________________

US State Dept Terrorism Report 2009

In 2009, Croatia started the drafting process for an action plan to
implement its national strategy for the prevention and suppression
of terrorism. Croatia expanded its extensive counterterrorism legal
framework by passing the Anti-Money Laundering and Terrorist
Financing Act, which entered into force in January.

In 2009, Croatia chaired the UN Security Council’s Counter-
Terrorism Committee (CTC). Croatia supported U.S. efforts in the
1267 Committee. Croatia also advocated providing further
financial support to the Counterterrorism Implementation Task
Force. The Croatian Interagency Working Group on Suppression
of Terrorism amended its mandate adding UNSCR 1624 to the
UNSC Resolutions it was already charged with implementing, such
as UNSCRs 1267, 1373, and 1566.

Croatia is currently issuing biometric passports. In addition,
Croatia signed a number of agreements in 2009 with the United
States that strengthened information sharing and cooperation
between U.S. and Croatian immigration, law enforcement, and
security agencies. Croatia also worked with the State Department’
s Export Control and Border Security program to improve security
along its 750 mile border with Serbia, Montenegro, and Bosnia, as
well as to monitor the country’s 6,000 miles of coastline.

The multinational Special Forces military exercise “Jackal Stone
09” held in September in Croatia had approximately 1,500
participants from 10 countries, including the United States, and
developed the capabilities of the participants in countering
terrorism.

During 2009, Croatia chaired the Council of Europe’s Committee
of Counterterrorism Experts (CODEXTER). Following up on a
Croatian initiative to develop cross-regional cooperation in
counterterrorism, the Council, Spain, and the Organization of
American States organized a Conference on Cyber Security in
Spain in April. Under CODEXTER’s umbrella, Croatia kept an
updated self-assessing Country Profile that summarized Croatia’s
counterterrorism activities.

Croatia worked closely with the OSCE’s Action against Terrorism
Unit. This resulted in a joint Croatian-OSCE workshop addressing
cyber-security issues such as terrorist use of the Internet, held in
Zagreb in November. More than 140 national representatives, as
well as 20 internationally recognized experts from academia,
business, and government, participated in this event.

As part of international efforts to counter violent extremists,
Croatia participated in the International Security Assistance Force
(ISAF) in Afghanistan, contributing approximately 300 troops.
Croatia joined NATO in April and began contributing to the
Alliance’s counterterrorism efforts.

____________________________________________________

Links:

Worldwide AML Legislation (International Bar Association)
Tables & Rankings
Are there Sanctions in force against it? (UN/EU/US)
EU/US
?
Is it on FATF list of non-cooperative countries?
N
?
Is it on OECD list of uncooperative Tax Havens?
N
?
OECD - Implementation status of Tax Standard
 
?
Is it on EU 'white' list of equivalent jurisdictions?
N
?
Offshore Finance Center (Original IMF List)?
N
?
Is it on the US Secretary of Treasury list of jurisdictions of
Primary Money Laundering concern?
N
?
Is it on the US Secretary of State list of jurisdictions
identified to be supporters of International Terrorism?
N
?
Is it on US Department of State International Narcotics
Control Majors List?
N
?
US Dept of State Money Laundering assessment (INCSR)
M
?
Government Actions (For further info see INCRS below):
 
?
-  Criminalized Drug Money Laundering?
Y
 
-  Criminalized Beyond Drugs?
Y
 
-  Record Large Transactions?
Y
 
-  Maintain Records Over Time?
Y
 
-  Report Suspicious Transactions?(NMP)?
Y
 
-  Egmont Financial Intelligence Units?
Y
 
-  System for Identifying/Forfeiting Assets?
Y
 
-  Arrangements for Asset Sharing?
N
 
-  Cooperates with International Law Enforcement?
Y
 
-  International Transportation of Currency?
Y
 
-  Ability to Freeze Terrorist Assets w/o Delay?
Y
 
-  Disclosure Protection "Safe Harbor"?
Y
 
-  Criminalized Financing of Terrorism?
Y
 
-  States Party to 1988 UN Convention?
Y
 
-  International Terrorism Financing Convention?
Y
 
 
Ranking
2011
Ranking
2010
 
Corruption (Transparency International)
66 (out of
183)
62 (out of
178)
?
Ease of doing business (World Bank)
80 (out of
183)
84 (out of
183)
?
FATF 40 + 9 recommendations
Mutual Evaluation Report: 2008
Further Tables
C
L
P
N
N/A
    C  -  Fully Compliant ,   
    L  -  Largely Compliant,    
    P  -  Partially Compliant    
    N  -  Non-Compliant
3
12
18
14
2
Legal Systems
 
1. Money Laundering Offence
P
 
14. Protection & no tipping-off
N
2. ML offence – mental element and
corporate liability
L
 
15. Internal controls,
compliance & audit
P
3. Confiscation and provisional
measures
P
 
16. DNFBP – R.13-15 & 21
N
4. Secrecy laws consistent with the
Recommendations
L
 
17. Sanctions
P
5. Customer due diligence
N
 
18. Shell banks
P
6. Politically exposed persons
N
 
19. Other forms of reporting
C
7. Correspondent banking
N
 
20. Other NFBP & secure
transaction techniques
P
8. New technologies & non
face-to-face business
N
 
21. Special attention for
higher risk countries
N
9. Third parties and introducers
N/A
 
22. Foreign branches &
subsidiaries
P
10. Record keeping
L
 
23. Regulation, supervision
and monitoring
P
11. Unusual transactions
N
 
24. DNFBP - regulation,
supervision and monitoring
N
12. Designated Non-Financial
Businesses and Professions – R.5,
6, 8-11
N
 
25. Guidelines & Feedback
P
13. Suspicious transaction reporting
P
     
Institutional and other
measures
 
26. The FIU
L
 
31. National co-operation
C
27. Law enforcement authorities
L
 
32. Statistics
P
28. Powers of competent authorities
C
 
33. Legal persons – beneficial
owners
P
29. Supervisors
L
 
34. Legal arrangements –
beneficial owners
N/A
30. Resources, integrity and training
L
 
 
 
International Co-operation
 
35. Conventions
P
 
38. MLA on confiscation and
freezing
L
36. Mutual legal assistance (MLA)
L
 
39. Extradition
L
37. Dual criminality
L
 
40. Other forms of
co-operation
L
Nine Special
Recommendations
 
SR.I Implement UN instruments
P
 
SR VI AML requirements for
money/value transfer services
N
SR.II Criminalise terrorist financing
P
 
SR VII Wire transfer rules
P
SR.III Freeze and confiscate terrorist
assets
N
 
SR.VIII Non profit
organisations
N
SR.IV Suspicious transaction
reporting
N
 
SR.IX Cross Border
Declaration & Disclosure
P
SR.V International co-operation
P
 
 
 
*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.
CROATIA
KnowYourCountry
-  Know Your Customer Provisions
Y
 
-  Criminalized Tipping Off?
Y
 
-  Report Suspected Terrorist Financing?
Y
 
-  State Party to United Nations TOC?
Y
 
-  State Party to United Nations CAC?
Y
 
Local AML News / Sanctions
Tax Information
Business Information
Last Updated:   16 April 2012