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US State Dept Narcotics Report 2012 (introduction):
Although levels of narcotic flows are difficult to assess, El Salvador is a
transit country for illegal drugs headed to the United States from
production countries in South America. The United States estimates that
approximately 95 percent of the cocaine leaving South America for the
United States moves through the Mexico and Central America corridor.
Of this, an increasing amount – nearly 80 percent – stops first in a Central
American country before onward shipment to Mexico. El Salvador was
named a major transit country for the first time in the President’s
September 2011 report to congress on Major Illicit Drug Producing and
Drug Transit Countries.
Traffickers in El Salvador used go-fast boats and commercial vessels to
smuggle illegal drugs along the coastline. Land transit primarily occurred
along the Pan-American Highway, with drugs hidden in the luggage of
bus passengers or in containers on commercial tractor-trailers. The
Cooperative Security Location at El Salvador’s international airport in
Comalapa was essential to regional detection and interception efforts
along both routes. Transnational street gangs were involved in street-
level drug sales but not major trafficking as part of the logistics supply
chain for Mexican, Colombian, and other drug trafficking organizations.
The Anti-Narcotics Division (DAN) of the National Civilian Police (PNC)
remained the primary law enforcement agency responsible for combating
illegal drug activity. The vetted special antinarcotics group (GEAN) within
the DAN handled the most complicated and time-consuming
investigations. The DAN was hampered by a lack of equipment, a
shortage of officers, and recurring funding gaps.
The Government of El Salvador reported the trafficking of precursor
chemicals used to manufacture synthetic drugs such as
methamphetamine. In 2011, the DAN seized 157 metric tons (MT) of
methamphetamine precursor chemicals and .17 kilograms (kg) of
methamphetamines. Local growers cultivated small quantities of
marijuana for domestic consumption. El Salvador is a party to the 1988
UN Drug Convention.
For Full report, click here
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US State Dept Trafficking in Persons Report 2011 (introduction):
(Tier 2)
El Salvador is a source, transit, and destination country for women and
children who are subjected to sex trafficking and forced labor. Women
and girls from rural areas of El Salvador are subjected to sex trafficking
in urban areas, sometimes by family members. Some Salvadoran adults
and children are subjected to forced labor in the agriculture and
domestic service sectors. The majority of foreign victims are women and
children from neighboring countries, such as Honduras, Nicaragua, and
Guatemala, who migrate to El Salvador in response to job offers, but are
subsequently forced into prostitution or domestic service. Traffickers use
fraudulent documentation to recruit and transport foreign victims.
Salvadorans have been subjected to sex trafficking and forced labor in
Guatemala, Mexico, Belize, Costa Rica, the United States, Spain, and
Italy. Organized criminal groups are reportedly involved in some
trafficking crimes in El Salvador.
The Government of El Salvador does not fully comply with the minimum
standards for the elimination of trafficking; however, it is making
significant efforts to do so. During the reporting period, the government
sustained anti-trafficking law enforcement efforts against sex trafficking
offenders and continued to provide comprehensive services to underage
victims of sex trafficking. It did not vigorously investigate or prosecute
incidents of forced labor or incidents of official complicity, however, nor
did it take adequate measures to ensure that adult trafficking victims
received access to necessary services.
For full report click here
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US State Dept Terrorism Report 2009
El Salvador hosts the U.S. government-funded International Law
Enforcement Academy, which provided instruction on counterterrorism,
transnational crime, alien trafficking, money laundering, and other topics
of counterterrorism interest. El Salvador also worked within the regional
Central American Integration System to promote effective regional
responses to transnational crime and other public security threats.
The Government of El Salvador was vigilant in its efforts to ensure that
Salvadoran territory was not used for recruitment, training, or terrorist
financing.
The principal Salvadoran counterterrorism entity, the National Civilian
Police, worked in close cooperation with the Salvadoran Immigration
Service, the Office of the Attorney General, and the Office of State
Intelligence, and was well regarded by U.S. counterparts. A 2006 statute
established strict criminal liability for engaging in terrorism, while other
statutes outlawed money laundering and terrorist financing.
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AML News / Updates
September 19, 2011 - El Salvador included in International Narcotics
Control Majors list
Read Press release
Links:
Worldwide AML Legislation (International Bar Association)
Bilateral exchange of information Agreements in place?
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Sanctions:
None applicable
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Offshore Jurisdiction Blacklists:
Information unavailable.
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US State Department Money Laundering Report - 2011:
El Salvador has an unusually rapidly growing banking system with
little, other than its dollarized economy and remittance flow, to
support such growth. The country is part of the transshipment
route for South American cocaine and heroin destined for the
United States and returning cash to South America. Money
laundering is primarily related to proceeds from illegal narcotics
and organized crime. There is no indication that money
laundering is being used to fund terrorist activities. The U.S.
dollar is the main currency in El Salvador. The country’s dollarized
economy and geographic location make it an ideal haven for
transnational organized crime groups, including human and drug
trafficking organizations. The Central America Four Agreement
between El Salvador, Guatemala, Honduras, and Nicaragua
allows for the free movement of citizens of these countries across
their respective borders without passing through immigration or
customs inspection. As such, the agreement represents a
vulnerability to each country for the cross-border movement of
contraband and illicit proceeds of crime.
There are 16 free trade zones operating in the country. There are
no reported hawala or other similar alternative remittance systems
operating in El Salvador. A significant number of remittances are
transferred through banks and appear to pose little risk for money
laundering.
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.: YES
CRIMINALIZATION OF MONEY LAUNDERING:
“All serious crimes” approach or “list” approach to predicate
crimes: All crimes
Legal persons covered: criminally: NO 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, agricultural credit institutions, money
exchanges, accountants, notaries, gaming centers, auto dealers,
and securities dealers
Enhanced due diligence procedures for PEPs: Foreign: YES
Domestic: YES
SUSPICIOUS TRANSACTION REPORTING REQUIREMENTS:
Covered entities: Banks, agricultural credit institutions, money
exchanges, accountants, notaries, gaming centers, auto dealers,
and securities dealers
Number of STRs received and time frame: 1,152 in 2010
Number of CTRs received and time frame: 2,562 in 2010
MONEY LAUNDERING CRIMINAL
PROSECUTIONS/CONVICTIONS:
Prosecutions: 29 in 2010
Convictions: Three in 2010
Assets forfeited: criminally: $14,655,926 in 2010 (one seizure
totaled $14,000,000)
civilly: Not available
RECORDS EXCHANGE MECHANISM:
With U.S.: YES
With other governments/jurisdictions: YES
El Salvador is a member of the Caribbean Financial Action Task
Force, a Financial Action Task Force-style regional body. Its most
recent mutual evaluation can be found here: http://www.cfatf-gafic.
org/downloadables/mer/El_Salvador_3rd_Round_MER_(Final)
_English.pdf
ENFORCEMENT AND IMPLEMENTATION ISSUES AND
COMMENTS:
The number of prosecutions relative to the number of crimes
which generate illicit funds is low. In addition, there are relatively
few asset seizures incident to AML investigations. Funds seized in
drugs cases are returned to law enforcement. In 2010, the
government passed asset forfeiture legislation that allows the
government to sell property seized in conjunction with narcotics
arrests and to use the profits for counter-narcotics efforts. The
regulatory institutions with regard to money laundering are weak
and lack both human resources and sufficient regulatory powers.
There are no indications that the government or its officials
facilitate or launder funds from illicit drug transactions. Salvadoran
law severely penalizes abuse of an official position in relation to
the commission of a drug offense, including accepting or receiving
money or other benefits in exchange for an act of commission or
omission relating to official duties.
El Salvador needs to provide a clear prohibition against “tipping
off” in its legislation and regulations, and clarify and enforce its
provisions regarding criminal liability for legal persons.
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Are there Sanctions in force against it? (UN/EU/US)
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Is it on FATF list of non-cooperative countries?
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Is it on OECD list of uncooperative Tax Havens?
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OECD - Implementation status of Tax Standard
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Is it on EU 'white' list of equivalent jurisdictions?
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Offshore Finance Center (Original IMF List)?
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Is it on the US Secretary of Treasury list of jurisdictions of Primary Money Laundering concern?
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Is it on the US Secretary of State list of jurisdictions identified to be supporters of International Terrorism?
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Is it on US Department of State International Narcotics Control Majors List?
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US Dept of State Money Laundering assessment (INCSR)
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Government Actions (For further info see INCRS below):
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- Criminalized Drug Money Laundering?
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- Criminalized Beyond Drugs?
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- Record Large Transactions?
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- Maintain Records Over Time?
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- Report Suspicious Transactions?(NMP)?
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- Egmont Financial Intelligence Units?
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- System for Identifying/Forfeiting Assets?
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- Arrangements for Asset Sharing?
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- Cooperates with International Law Enforcement?
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- International Transportation of Currency?
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- Ability to Freeze Terrorist Assets w/o Delay?
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- Disclosure Protection "Safe Harbor"?
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- Criminalized Financing of Terrorism?
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- States Party to 1988 UN Convention?
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- International Terrorism Financing Convention?
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Compliance with FATF 40 + 9 recommendations
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% Fully or Largely Compliant
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Corruption (Transparency International)
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Ease of doing business (World Bank)
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- Know Your Customer Provisions
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- Criminalized Tipping Off?
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- Report Suspected Terrorist Financing?
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- State Party to United Nations TOC?
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- State Party to United Nations CAC?
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Local AML News / Sanctions
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Last Updated: 16 April 2012
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