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FATF Statement re AML Strategic Deficiencies:
Date: 16 February 2012
Ghana has taken steps towards improving its AML/CFT regime,
including by ratifying the UN Convention on Transnational
Organised Crime and issuing CDD guidelines. Despite Ghana’s
high-level political commitment to work with the FATF and GIABA
to address its strategic AML/CFT deficiencies, Ghana has not
made sufficient progress in implementing its action plan, and
certain strategic AML/CFT deficiencies remain. Ghana should
work on implementing its action plan to address these
deficiencies, including by: (1) adequately criminalising money
laundering and terrorist financing (Recommendation 1 and
Special Recommendation II); (2) establishing and implementing
adequate measures for the confiscation of funds related to money
laundering (Recommendation 3); (3) establishing a fully
operational and effectively functioning Financial Intelligence Unit
(Recommendation 26); and (4) establishing and implementing
adequate procedures to identify and freeze terrorist assets
(Special Recommendation III). The FATF encourages Ghana to
address its remaining deficiencies and continue the process of
implementing its action plan.
____________________________________________________
Sanctions:
None applicable
____________________________________________________
Offshore Jurisdiction Blacklists – Further Information:
As a recognised offshore finance jurisdiction this country may fall
under various country offshore jurisdiction blacklists.
____________________________________________________
US State Department Money Laundering Report - 2011:
Ghana is not a regional financial center, but as it develops
economically its financial sector is becoming more important
regionally. Most of the money laundering in Ghana involves
narcotics or public corruption. Ghana is a significant
transshipment point for cocaine and heroin transiting from South
America, Iran and Afghanistan to Europe and the United States.
Public corruption is a major source of money laundering in
Ghana, occurring mainly through public procurements and the
award of licenses. Criminals also launder illicit proceeds through
investment in banking, insurance, real estate, automotive import,
and general import businesses, and reportedly, donations to
religious institutions. Financial crimes such as advance fee fraud,
known as Sakawa in Ghana, stolen credit and ATM cards
originating in Ghana, and check cloning continue to increase.
Informal financial activity accounts for about 45 percent of the
total Ghanaian economy. Some traders import counterfeit goods
or smuggle goods to evade taxes. In most cases the smugglers
bring the goods into the country in small quantities, and Ghanaian
authorities have no indication these smugglers have links to
criminals who want to launder proceeds from narcotics or
corruption. Trade-based money laundering is sometimes used to
repatriate “profit” and also for payment of lower customs duties
and other taxes.
In September 2007, following amendments to the Banking Act,
Barclays Bank set up the first offshore banking facility in Ghana.
Regulations governing domestic and offshore banks are largely
similar. Both are required to perform customer due diligence and
file suspicious transaction reports (STRs). Ghana has designated
four free trade zone (FTZ) areas, but the Tema Export Processing
Zone is currently the only active FTZ. Ghana also licenses
factories outside the FTZ area as free zone companies. Free
zone companies must export at least 70 percent of their output.
Most of these companies produce garments and processed
foods. The Ghana Free Zone Board and the immigration and
customs authorities monitor these companies. There are
identification requirements for companies, individuals, and their
vehicles in the free zone; however, monitoring and due diligence
procedures are lax.
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: Both
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
(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, insurance and securities firms, casinos,
auctioneers, notaries, lawyers, non-governmental organizations,
accountants, religious bodies, real estate developers, operators
of games of chance, trust and company service providers,
businesses engaged in providing financial services that involve
the remittance or exchange of funds, dealers in motor vehicles,
dealers in precious minerals and stones
Enhanced due diligence procedures for PEPs: Foreign: NO
Domestic: YES
SUSPICIOUS TRANSACTION REPORTING REQUIREMENTS:
Covered entities: Banks, insurance and securities firms, casinos,
auctioneers, notaries, lawyers, non-governmental organizations,
accountants, religious bodies, real estate developers, operators
of games of chance, trust and company service providers,
businesses engaged in providing financial services that involve
the remittance or exchange of funds, dealers in motor vehicles,
dealers in precious minerals and stones
Number of STRs received and time frame: 50 from January 2010
to November 2010
Number of CTRs received and time frame: 0 from January 2010 to
November 2010
MONEY LAUNDERING CRIMINAL
PROSECUTIONS/CONVICTIONS:
Prosecutions: 0
Convictions: 0
Assets forfeited: criminally: 0 civilly: 0
RECORDS EXCHANGE MECHANISM:
With U.S.: YES
With other governments/jurisdictions: YES
Ghana is a member of the Intergovernmental Action Group
against Money Laundering in West Africa (GIABA), a Financial
Action Task Force (FATF)-style regional body. Its most recent
mutual evaluation can be found here: www.giaba.org
ENFORCEMENT AND IMPLEMENTATION ISSUES AND
COMMENTS:
There are six law enforcement agencies involved in investigating
money laundering and financial crimes.
In 2010, the Government of Ghana (GOG) took significant steps
to establish its Financial Intelligence Center, and passed an
Economic and Organized Crime Office Act and Mutual Legal
Assistance Act. To remedy deficiencies, the GOG is working to
pass subsidiary legislation, which should improve capacity among
the agencies impacted. The GOG should make every effort to
pass asset seizure and forfeiture legislation that comports with
international standards as soon as possible. Once the laws are in
place, Ghana should take the necessary steps to promote public
awareness and understanding of financial crime, money
laundering and terrorist financing activities. Additionally, the GOG
should fully implement its customer due diligence and reporting
requirements across all covered sectors and institute a beneficial
ownership identification requirement, requiring the true names of
all onshore and offshore entities and their beneficial owners to be
held in a registry accessible to law enforcement. The GOG should
increase cooperation and information sharing with other
governments. Ghana should also become a party to the UN
Convention against Transnational Organized Crime.
______________________________________________
US State Dept Narcotics Report 2012 (introduction):
Ghana continues to be a transshipment point for illegal drugs,
particularly cocaine from South America, as well as heroin from
Afghanistan and Pakistan. Europe is the major destination, but
drugs also flow to South Africa and to North America. Accra’s
Kotoka International Airport (KIA) is a focus for traffickers. Ports at
Tema and Takoradi are also used, and border posts at Aflao
(Togo) and Elubo and Sampa (Cote d’Ivoire) have seen significant
drug trafficking activity. Gangs trafficking South American cocaine
have increased their foothold in Ghana, establishing distribution
networks run by Nigerian and Ghanaian criminals. Ghana’s
interest in attracting investment provides good cover for foreign
drug barons to enter the country under the guise of legitimate
business. However, South American traffickers limit their personal
involvement in Ghana by relying on local partners, thus insulating
themselves from possible arrest by local authorities.
Trafficking has fueled increasing domestic drug consumption of
methamphetamine. Government regulation and oversight of
precursor chemicals are inadequate.
President John Atta Mills remains committed to combating narco-
trafficking in Ghana, most recently speaking against the illicit drug
trade before the 66th session of the U.N. General Assembly in
September 2011. He has promised to re-examine two high-profile
narcotics cases from the previous administration and has
continued to provide material support to law enforcement.
Corruption, a lack of resources, and porous borders seriously
impede interdiction efforts. While law enforcement authorities
continue to arrest low-level narcotics traffickers, Ghana has had
relatively less success pursuing the so-called drug barons.
Narcotics-related cases and others involving serious crimes can
sometimes take years to prosecute, due to lack of expertise for
prosecutors and judges, overbooked attorneys and the failure of
witnesses to appear in court. Interagency coordination among law
enforcement agencies remains a challenge. Ghana is a party to
the 1988 UN Drug Convention.
For Full report, click here
____________________________________________________
US State Dept Trafficking in Persons Report 2011
(introduction):
(Tier 2)
Ghana is a country of origin, transit, and destination for women
and children subjected to forced labor and sex trafficking. The
trafficking of Ghanaian citizens, particularly children, within the
country is more common than the transnational trafficking of
foreign migrants. This internal trafficking is characterized largely
by the movement of children from rural to urban areas or from
one rural area to another, such as from farming to fishing
communities. Ghanaian boys and girls are subjected to conditions
of forced labor within the country in fishing, domestic service,
street hawking, begging, portering, and agriculture. Ghanaian
girls, and to a lesser extent boys, are subjected to prostitution
within Ghana. There were reports that Labadi Beach in Accra, as
well as Cape Coast and Elmina, may be destinations for
international child sex tourists. Ghanaian women and children are
recruited and transported to Nigeria, Cote d’Ivoire, Burkina Faso,
The Gambia, Russia, Syria, Lebanon, South Africa, the United
States, and countries in Western Europe for forced labor and sex
trafficking. Women and girls, voluntarily migrating from China,
Nigeria, Cote d’Ivoire, Burkina Faso, Benin, and possibly Romania
are subjected to commercial sexual exploitation after arriving in
Ghana. Citizens from other West African countries and from
Bangladesh are subjected to forced labor in Ghana in agriculture
or domestic service.
The Government of Ghana does not fully comply with the
minimum standards for the elimination of trafficking; however, it is
making significant efforts to do so. The government demonstrated
an increased ability to collect data on trafficking victims identified
and reported knowledge of 482 such victims in 2010. However,
despite this substantial figure, it initiated only six prosecutions and
obtained four convictions of trafficking offenders during the year –
a decline in prosecution efforts from the previous year – and it
failed to provide information on the number of trafficking victims
that it referred to protective services. Despite the government’s
recognition that the majority of trafficking occurred within the
country, authorities only prosecuted two such cases of internal
trafficking during the reporting period.
For full report click here
____________________________________________________
US State Dept Terrorism Report 2009
In 2008, Ghana enacted the Counterterrorism Act, which called for
implementation of a national identification card. The cards will
contain biometric data such as fingerprints and photos, but the
national identification card has not yet been introduced. Forms of
identification with biometrics were not in widespread use, although
the Ghanaian driver’s license is issued with a fingerprint as part of
the individual’s application. Most citizens use their voter
registration card and a passport for identification. In 2009,
Ghanaian passports issued were machine readable but lacked
biometric features.
Ghana passed an anti-money laundering law in 2008 that
provided for the establishment of a Financial Intelligence Unit
(FIU). At the end of 2009, the FIU was not yet operational.
However, six potential FIU members, including the Chief Executive
Officer, were identified and sent to the United States for training.
U.S. Africa Command provided technical and training assistance
to the Ghanaian Navy for the three “Defender” class patrol boats
they received in 2008 and the additional four boats delivered in
December. The patrol boats are intended to improve maritime
interdiction capacity and to address Ghana’s limited ability to
patrol its porous borders.
The Governments of Ghana and Togo signed an agreement in
October to cooperate on crime and security problems such as
human trafficking, small weapons trafficking, money laundering,
and counterterrorism. The agreement is part of a larger strategy
to accelerate regional integration and the free movement of
persons, goods, and services; and to intensify trade and
economic relations within the sub-region.
Date: 16 February 2012
Ghana has taken steps towards improving its AML/CFT regime,
including by ratifying the UN Convention on Transnational
Organised Crime and issuing CDD guidelines. Despite Ghana’s
high-level political commitment to work with the FATF and GIABA
to address its strategic AML/CFT deficiencies, Ghana has not
made sufficient progress in implementing its action plan, and
certain strategic AML/CFT deficiencies remain. Ghana should
work on implementing its action plan to address these
deficiencies, including by: (1) adequately criminalising money
laundering and terrorist financing (Recommendation 1 and
Special Recommendation II); (2) establishing and implementing
adequate measures for the confiscation of funds related to money
laundering (Recommendation 3); (3) establishing a fully
operational and effectively functioning Financial Intelligence Unit
(Recommendation 26); and (4) establishing and implementing
adequate procedures to identify and freeze terrorist assets
(Special Recommendation III). The FATF encourages Ghana to
address its remaining deficiencies and continue the process of
implementing its action plan.
____________________________________________________
Sanctions:
None applicable
____________________________________________________
Offshore Jurisdiction Blacklists – Further Information:
As a recognised offshore finance jurisdiction this country may fall
under various country offshore jurisdiction blacklists.
____________________________________________________
US State Department Money Laundering Report - 2011:
Ghana is not a regional financial center, but as it develops
economically its financial sector is becoming more important
regionally. Most of the money laundering in Ghana involves
narcotics or public corruption. Ghana is a significant
transshipment point for cocaine and heroin transiting from South
America, Iran and Afghanistan to Europe and the United States.
Public corruption is a major source of money laundering in
Ghana, occurring mainly through public procurements and the
award of licenses. Criminals also launder illicit proceeds through
investment in banking, insurance, real estate, automotive import,
and general import businesses, and reportedly, donations to
religious institutions. Financial crimes such as advance fee fraud,
known as Sakawa in Ghana, stolen credit and ATM cards
originating in Ghana, and check cloning continue to increase.
Informal financial activity accounts for about 45 percent of the
total Ghanaian economy. Some traders import counterfeit goods
or smuggle goods to evade taxes. In most cases the smugglers
bring the goods into the country in small quantities, and Ghanaian
authorities have no indication these smugglers have links to
criminals who want to launder proceeds from narcotics or
corruption. Trade-based money laundering is sometimes used to
repatriate “profit” and also for payment of lower customs duties
and other taxes.
In September 2007, following amendments to the Banking Act,
Barclays Bank set up the first offshore banking facility in Ghana.
Regulations governing domestic and offshore banks are largely
similar. Both are required to perform customer due diligence and
file suspicious transaction reports (STRs). Ghana has designated
four free trade zone (FTZ) areas, but the Tema Export Processing
Zone is currently the only active FTZ. Ghana also licenses
factories outside the FTZ area as free zone companies. Free
zone companies must export at least 70 percent of their output.
Most of these companies produce garments and processed
foods. The Ghana Free Zone Board and the immigration and
customs authorities monitor these companies. There are
identification requirements for companies, individuals, and their
vehicles in the free zone; however, monitoring and due diligence
procedures are lax.
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: Both
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
(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, insurance and securities firms, casinos,
auctioneers, notaries, lawyers, non-governmental organizations,
accountants, religious bodies, real estate developers, operators
of games of chance, trust and company service providers,
businesses engaged in providing financial services that involve
the remittance or exchange of funds, dealers in motor vehicles,
dealers in precious minerals and stones
Enhanced due diligence procedures for PEPs: Foreign: NO
Domestic: YES
SUSPICIOUS TRANSACTION REPORTING REQUIREMENTS:
Covered entities: Banks, insurance and securities firms, casinos,
auctioneers, notaries, lawyers, non-governmental organizations,
accountants, religious bodies, real estate developers, operators
of games of chance, trust and company service providers,
businesses engaged in providing financial services that involve
the remittance or exchange of funds, dealers in motor vehicles,
dealers in precious minerals and stones
Number of STRs received and time frame: 50 from January 2010
to November 2010
Number of CTRs received and time frame: 0 from January 2010 to
November 2010
MONEY LAUNDERING CRIMINAL
PROSECUTIONS/CONVICTIONS:
Prosecutions: 0
Convictions: 0
Assets forfeited: criminally: 0 civilly: 0
RECORDS EXCHANGE MECHANISM:
With U.S.: YES
With other governments/jurisdictions: YES
Ghana is a member of the Intergovernmental Action Group
against Money Laundering in West Africa (GIABA), a Financial
Action Task Force (FATF)-style regional body. Its most recent
mutual evaluation can be found here: www.giaba.org
ENFORCEMENT AND IMPLEMENTATION ISSUES AND
COMMENTS:
There are six law enforcement agencies involved in investigating
money laundering and financial crimes.
In 2010, the Government of Ghana (GOG) took significant steps
to establish its Financial Intelligence Center, and passed an
Economic and Organized Crime Office Act and Mutual Legal
Assistance Act. To remedy deficiencies, the GOG is working to
pass subsidiary legislation, which should improve capacity among
the agencies impacted. The GOG should make every effort to
pass asset seizure and forfeiture legislation that comports with
international standards as soon as possible. Once the laws are in
place, Ghana should take the necessary steps to promote public
awareness and understanding of financial crime, money
laundering and terrorist financing activities. Additionally, the GOG
should fully implement its customer due diligence and reporting
requirements across all covered sectors and institute a beneficial
ownership identification requirement, requiring the true names of
all onshore and offshore entities and their beneficial owners to be
held in a registry accessible to law enforcement. The GOG should
increase cooperation and information sharing with other
governments. Ghana should also become a party to the UN
Convention against Transnational Organized Crime.
______________________________________________
US State Dept Narcotics Report 2012 (introduction):
Ghana continues to be a transshipment point for illegal drugs,
particularly cocaine from South America, as well as heroin from
Afghanistan and Pakistan. Europe is the major destination, but
drugs also flow to South Africa and to North America. Accra’s
Kotoka International Airport (KIA) is a focus for traffickers. Ports at
Tema and Takoradi are also used, and border posts at Aflao
(Togo) and Elubo and Sampa (Cote d’Ivoire) have seen significant
drug trafficking activity. Gangs trafficking South American cocaine
have increased their foothold in Ghana, establishing distribution
networks run by Nigerian and Ghanaian criminals. Ghana’s
interest in attracting investment provides good cover for foreign
drug barons to enter the country under the guise of legitimate
business. However, South American traffickers limit their personal
involvement in Ghana by relying on local partners, thus insulating
themselves from possible arrest by local authorities.
Trafficking has fueled increasing domestic drug consumption of
methamphetamine. Government regulation and oversight of
precursor chemicals are inadequate.
President John Atta Mills remains committed to combating narco-
trafficking in Ghana, most recently speaking against the illicit drug
trade before the 66th session of the U.N. General Assembly in
September 2011. He has promised to re-examine two high-profile
narcotics cases from the previous administration and has
continued to provide material support to law enforcement.
Corruption, a lack of resources, and porous borders seriously
impede interdiction efforts. While law enforcement authorities
continue to arrest low-level narcotics traffickers, Ghana has had
relatively less success pursuing the so-called drug barons.
Narcotics-related cases and others involving serious crimes can
sometimes take years to prosecute, due to lack of expertise for
prosecutors and judges, overbooked attorneys and the failure of
witnesses to appear in court. Interagency coordination among law
enforcement agencies remains a challenge. Ghana is a party to
the 1988 UN Drug Convention.
For Full report, click here
____________________________________________________
US State Dept Trafficking in Persons Report 2011
(introduction):
(Tier 2)
Ghana is a country of origin, transit, and destination for women
and children subjected to forced labor and sex trafficking. The
trafficking of Ghanaian citizens, particularly children, within the
country is more common than the transnational trafficking of
foreign migrants. This internal trafficking is characterized largely
by the movement of children from rural to urban areas or from
one rural area to another, such as from farming to fishing
communities. Ghanaian boys and girls are subjected to conditions
of forced labor within the country in fishing, domestic service,
street hawking, begging, portering, and agriculture. Ghanaian
girls, and to a lesser extent boys, are subjected to prostitution
within Ghana. There were reports that Labadi Beach in Accra, as
well as Cape Coast and Elmina, may be destinations for
international child sex tourists. Ghanaian women and children are
recruited and transported to Nigeria, Cote d’Ivoire, Burkina Faso,
The Gambia, Russia, Syria, Lebanon, South Africa, the United
States, and countries in Western Europe for forced labor and sex
trafficking. Women and girls, voluntarily migrating from China,
Nigeria, Cote d’Ivoire, Burkina Faso, Benin, and possibly Romania
are subjected to commercial sexual exploitation after arriving in
Ghana. Citizens from other West African countries and from
Bangladesh are subjected to forced labor in Ghana in agriculture
or domestic service.
The Government of Ghana does not fully comply with the
minimum standards for the elimination of trafficking; however, it is
making significant efforts to do so. The government demonstrated
an increased ability to collect data on trafficking victims identified
and reported knowledge of 482 such victims in 2010. However,
despite this substantial figure, it initiated only six prosecutions and
obtained four convictions of trafficking offenders during the year –
a decline in prosecution efforts from the previous year – and it
failed to provide information on the number of trafficking victims
that it referred to protective services. Despite the government’s
recognition that the majority of trafficking occurred within the
country, authorities only prosecuted two such cases of internal
trafficking during the reporting period.
For full report click here
____________________________________________________
US State Dept Terrorism Report 2009
In 2008, Ghana enacted the Counterterrorism Act, which called for
implementation of a national identification card. The cards will
contain biometric data such as fingerprints and photos, but the
national identification card has not yet been introduced. Forms of
identification with biometrics were not in widespread use, although
the Ghanaian driver’s license is issued with a fingerprint as part of
the individual’s application. Most citizens use their voter
registration card and a passport for identification. In 2009,
Ghanaian passports issued were machine readable but lacked
biometric features.
Ghana passed an anti-money laundering law in 2008 that
provided for the establishment of a Financial Intelligence Unit
(FIU). At the end of 2009, the FIU was not yet operational.
However, six potential FIU members, including the Chief Executive
Officer, were identified and sent to the United States for training.
U.S. Africa Command provided technical and training assistance
to the Ghanaian Navy for the three “Defender” class patrol boats
they received in 2008 and the additional four boats delivered in
December. The patrol boats are intended to improve maritime
interdiction capacity and to address Ghana’s limited ability to
patrol its porous borders.
The Governments of Ghana and Togo signed an agreement in
October to cooperate on crime and security problems such as
human trafficking, small weapons trafficking, money laundering,
and counterterrorism. The agreement is part of a larger strategy
to accelerate regional integration and the free movement of
persons, goods, and services; and to intensify trade and
economic relations within the sub-region.
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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.
| GHANA |
| KnowYourCountry |
|
___________________________________________________
AML News / Updates
May 1, 2011 - New report by the Global Forum on Transparency and
Exchange of Information to evaluate the country's legal and regulatory
frameworks for re exchange of information is made available.
Read Report....
Links:
Worldwide AML Legislation (International Bar Association)
AML News / Updates
May 1, 2011 - New report by the Global Forum on Transparency and
Exchange of Information to evaluate the country's legal and regulatory
frameworks for re exchange of information is made available.
Read Report....
Links:
Worldwide AML Legislation (International Bar Association)
|
| Last Updated: 16 April 2012 |