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    Guernsey
FATF Statement re AML Strategic Deficiencies:

Date:  27 June 2011

The FATF welcomes Greece’s significant progress in improving its
AML/CFT regime and notes that Greece has met its commitments
in its Action Plan regarding the strategic AML/CFT deficiencies
that the FATF had identified in February 2010. Greece is
therefore no longer subject to FATF’s monitoring process under
its on-going global AML/CFT compliance process. Greece will
work with the FATF in further strengthening its AML/CFT regime.

____________________________________________________

Sanctions:

None applicable

____________________________________________________

Offshore Jurisdiction Blacklists:

Yes, but no further information currently available.

____________________________________________________

US State Department Money Laundering Report - 2012:

Greece is considered to be a regional financial center in the
developing Balkans, as well as a bridge between Europe and the
Middle East. Official corruption, the presence of organized crime,
and a large shadow economy make the country vulnerable to
money laundering and terrorist financing. Greek law enforcement
proceedings indicate that Greece is vulnerable to narcotics
trafficking, trafficking in persons and illegal immigration,
prostitution, smuggling of cigarettes and other contraband,
serious fraud or theft, illicit gaming activities, and large scale tax
evasion. Anecdotal evidence of illicit transactions suggests an
increase in financial crimes in the past few years and that criminal
organizations (some with links to terrorist groups) increasingly are
trying to use the Greek banking system to launder illicit proceeds.
Criminally-derived proceeds historically are most commonly
invested in real estate, the lottery, and the stock market. Criminal
organizations from southeastern Europe and the Balkan region
are responsible for a large percentage of the crime that
generates illicit funds. The widespread use of cash facilitates a
gray economy as well as tax evasion, though as part of Greece’s
reform commitments under its European Union (EU)-IMF bailout
program, the government is trying to crack down on both trends.
Due to the large informal economy – estimated by the
Organization for Economic Co-operation and Development and
others to be between 25 and 37 percent of GDP – it is difficult to
determine the value of goods smuggled into the country, including
whether any of the smuggled goods are funded by narcotic or
other illicit proceeds. There is increasing evidence that domestic
terrorist groups are involved with drug trafficking.

For additional information focusing on terrorist financing, please
refer to the Department of State’s Country Reports on Terrorism,
which can be found here: http://www.state.gov/j/ct/rls/crt/

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: A combination of a list of predicate offenses and a
threshold approach

Legal persons covered: criminally: NO civilly: YES

Know-your-customer (KYC) rules:

Enhanced due diligence procedures for PEPs: Foreign: YES
Domestic: NO

KYC covered entities: Banks, savings banks, and cooperative
banks; credit companies, money remitters, financial leasing and
factoring companies, bureaux de change, and postal companies;
stock brokers, investment services firms, and collective and
mutual funds; life insurance companies and insurance
intermediaries; accountants, auditors, and audit firms; tax
consultants, tax experts, and related firms; real estate agents and
companies; casinos (including internet casinos) and entities
engaging in gaming activities; auction houses, dealers in high
value goods, auctioneers, and pawnbrokers; notaries, lawyers,
and persons providing services to companies and trusts

Suspicious Transaction Reporting (STR) Requirements:

Number of STRs received and time frame: 3,479 in 2011

Number of CTRs received and time frame: Not available

STR covered entities: Banks, savings banks, and cooperative
banks; credit companies, money remitters, financial leasing and
factoring companies, bureaux de change, and postal companies;
stock brokers, investment services firms, and collective and
mutual funds; life insurance companies and insurance
intermediaries; accountants, auditors and audit firms; tax
consultants, tax experts and related firms; real estate agents and
companies; casinos (including internet casinos) and entities
engaging in gaming activities; auction houses, dealers in high
value goods, auctioneers, and pawnbrokers; notaries, lawyers,
and persons providing services to companies and trusts

Money Laundering Criminal Prosecutions/Convictions:

Prosecutions: 134 in 2011

Convictions: 58 in the first half of 2011

Records exchange mechanism:

With U.S.: MLAT: YES Other mechanism: YES

With other governments/jurisdictions: YES

Greece is a member of the Financial Action Task Force (FATF). Its
most recent mutual evaluation can be found here: http://www.fatf-
afi.org/document/23/0,3343,
en_32250379_32236963_38916695_1_1_1_1,00.html

Enforcement and implementation issues and comments:

The Government of Greece (GOG) has been working to improve
the effectiveness of the Greek financial intelligence unit (FIU).
Greek authorities have hired sufficient staff to carry out the
extensive functions with which the FIU is tasked. The GOG has
also made available adequate financial resources to ensure the
FIU is able to fulfill its responsibilities, ensure its powers are in line
with the international standards related to a financial intelligence
unit, and ensure its technical and data management systems and
capacities support its functions.

Greece still needs to ensure that its confiscation regime is more
effectively implemented and used. While the 2008 anti-money
laundering/countering the financing of terrorism (AML/CFT) law
contains provisions allowing civil asset forfeiture under special
circumstances, Greek authorities advise it is not practical to
launch civil procedures and currently do not do so. The
government also should develop an arrangement for the sharing
of seized assets with third party jurisdictions that assist in the
conduct of investigations.

In March 2011, an amendment to the 2008 AML/CFT law (Law
3932/A49/10-3-2011) established a new entity, the Financial
Sanctions Unit (FSU). The FSU is tasked with designating
terrorists in accordance with UNSCR 1373, outside the EU listing
system, and issuing executive orders to freeze the assets of
internationally designated terrorists. It is unclear if the executive
order procedure applies to suspected terrorists designated
domestically. The GOG has provided guidance to financial
institutions and designated non-financial businesses and
professions on freezing assets without delay, and has begun to
monitor for compliance, though the effectiveness of the monitoring
is still undetermined. The GOG is authorized to impose sanctions
on entities for noncompliance with freeze orders.

While Greece has made positive strides in the supervision area,
particularly with its transfer of supervisory powers over the
insurance sector to the Bank of Greece, a shortage of personnel
at the Hellenic Capital Markets Commission (which supervises
securities firms, brokers, other financial intermediaries, and
clearing houses) remains, but is difficult to address in light of a
general hiring freeze in the public sector due to Greece’s debt
crisis. It also remains unclear whether the Ministry of Justice has
enough resources available to deal with money laundering or
terrorist finance related cases.

The GOG has instituted regulatory measures requiring that
transactions above €3,000 (approximately $3,850) be executed
with credit cards, checks or cashiers’ checks and that all business-
to-business transactions in excess of €3,000 (approximately
$3,850) be carried out through checks or bank account transfers.
All credit and financial institutions, including payment institutions,
must also report on a monthly basis all transfers of funds abroad
executed by credit card, check or wire transfer. Nevertheless, the
GOG should adopt a system for reporting large currency
transactions across all regulated sectors and explicitly abolish
company-issued bearer shares. It should also continue to improve
enforcement of its cross-border currency reporting requirements
and improve efforts to deter the smuggling of currency across its
borders. Greece also should ensure that companies operating
within its free trade zones are subject to the same level of
enforcement of AML/CFT controls as other sectors and work
steadfastly to bring charitable and nonprofit organizations under
the AML/CFT regime.

____________________________________________________

US State Dept Narcotics Report 2011 (introduction):

No report available

____________________________________________________

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

(Tier 2)

Greece is a transit and destination country for women and
children subjected to sex trafficking and for men, women, and
children who are in conditions of forced labor. The Greek
government and NGOs report female sex trafficking victims
originate primarily in Eastern Europe, the Balkans, Nigeria, and
Central Asia. One NGO reported teenage males, typically
unaccompanied children from Afghanistan, Pakistan, Somalia,
and other countries in sub-Saharan Africa, are subjected to
prostitution in Greece. Ninety percent of all illegal migrants
entering the EU currently enter through Greece, a trend that
poses additional challenges to Greek authorities in monitoring
severe forms of trafficking. Greek police report a trend in which
traffickers used psychological abuse and threats of financial harm
instead of physical force as tools of coercion in attempts to evade
legal prosecution. Forced labor victims found in Greece originated
primarily in Albania, Romania, Bulgaria, Moldova, Afghanistan,
Pakistan, India, and Bangladesh, and reportedly were forced to
work primarily in the agriculture or construction sectors in debt
bondage. Greek police estimated there likely are hundreds of
forced labor victims in Greece. NGOs reported children, mainly
Roma from Albania, Bulgaria, and Romania, were forced to sell
small items, beg, or steal. Unaccompanied minors, many of whom
paid large smuggling fees, remained highly vulnerable to human
trafficking.

The Government of Greece does not fully comply with the
minimum standards for the elimination of trafficking; however, it is
making significant efforts to do so. Following its ratification of the
2000 UN TIP Protocol, the Greek government enacted
comprehensive victim-centered legislation that includes stronger
tools such as: a lengthened reflection period; increased flexibility
in victim certification; and improved temporary and long-term
residency options for trafficking victims. During the year, the
government sustained its progress in prosecuting labor and sex
trafficking offenses and disrupting major trafficking networks by
using advanced investigative techniques in collaboration with
international partners and local entities. Law enforcement
agencies responded to trafficking cases in a manner consistent
with the vigorous investigation and prosecution of these crimes.
The Ministry of Justice did not report any suspended sentences
given to convicted trafficking offenders. Nevertheless, the
government’s de facto provision of victim protection remained
weak. Greek police arrested 246 trafficking offenders in the last
year, but officially certified only 30 victims for victim care during
the same time period. In the face of financial restrictions,
government funding of victim protection efforts and shelters
remained limited. The judiciary continued to suffer from structural
and legal inefficiencies that resulted in low conviction rates for
most prosecuted offenders. NGOs alleged instances of unethical
behavior by defense lawyers, which reportedly further slowed the
judicial process and subjected affected victims of trafficking to
threats. One high-profile police complicity case has remained
unresolved since 2006.

For full report click here

____________________________________________________

US State Dept Terrorism Report 2010

Overview: Large cities in Greece continued to face a significant
challenge from domestic terrorism. Throughout the year in Athens
and Thessaloniki, anarchists attacked banks, police stations, the
homes and offices of politicians, and other “imperialist-capitalist”
targets with weapons such as improvised explosive devices and
Molotov cocktails. Police arrested suspected members of
Revolutionary Struggle, but attacks by other terrorist groups
continued, resulting in six deaths. Of the six, two were killed by
bombings, one in a targeted killing, and three in an arson attack
on a bank.

2010 Terrorist Incidents: Athens and Thessaloniki together
experienced hundreds of security incidents, including incendiary
and explosive strikes, as well as attacks involving small arms,
grenades, and other infantry-style weaponry. Extremists struck
businesses, Greek law enforcement, journalists, embassies, and
for the first time, targets outside of Greece. Some of the more
significant attacks included:

* Conspiracy of Fire Nuclei claimed responsibility for a continuing
series of attacks in March, May, November, and December that
targeted political groups, foreign embassies, leaders of foreign
governments, and symbols of the Greek state.
* A bomb left outside the Athens office of a corporate
management company killed a fifteen-year-old Afghan immigrant
boy on March 28 and blinded his younger sister, when he
apparently when he triggered the bomb by accident. The
perpetrators remained unknown.
* A parcel bomb, addressed to Minister of Citizen Protection
Michalis Chrysochoidis, killed Chrysochoidis’s aide, police
Lieutenant Colonel Yorgos Vassilakis, on June 24 at Ministry of
Citizen Protection headquarters. An anonymous group claimed
responsibility.
* Sect of Revolutionaries claimed responsibility for the July 19
assassination of blogger and radio station executive Sokratis
Giolias outside his residence in Athens – the group’s first
operation after 13 months of inactivity – and threatened further
attacks against police, government employees, journalists, and
others as part of a stated desire to turn Greece into a “war zone.”

Legislation and Law Enforcement: The following arrests/court
actions occurred in 2010:

* In April, police arrested six suspected members of the domestic
terrorist organization Revolutionary Struggle (RS), after following
the trail of physical evidence obtained at the scene of a deadly
shootout between police and suspects in suburban Athens on
March 9. In addition to the arrests, police discovered sites
associated with the group, which contained extensive evidence,
including bombs, ammunition, attack plans, and the rocket
launcher RS is believed to have used in an attack on the U.S.
Embassy in 2007.
* On July 26, the Supreme Court rejected final appeals by six
convicted members of the Revolutionary Organization 17
November (17N), which was responsible for deaths of 23 people
between 1975 and 2002. The Court sent the cases of two less
prominent 17N convicts back to a lower court for review.
* On November 1, police arrested two suspected members of
Conspiracy of Fire Nuclei in Athens soon after they had dropped
off parcel improvised explosive devices (IEDs) at a courier service
office. The two suspects were carrying two unsent parcel IEDs in a
backpack when they were detained by Greek authorities.

Greek authorities participated in the Container Security Initiative
and cooperated with U.S. officials on information sharing, as well
as the training of Greek security and customs officials, and judicial
personnel. Greece continued to work with the EU border agency
FRONTEX to strengthen border security.

Countering Terrorist Finance: Since a critical 2007 Financial
Action Task Force (FATF) report, Greek authorities have made
substantial progress in meeting shortcomings identified by FATF,
including passing a new anti-money laundering/counterterrorist
finance law that addressed most of the FATF recommendations.
Most recently, Greece ratified the UN Convention against
Transnational Organized Crime and amended its law to criminalize
and broadly define terrorist finance offenses. The government
drafted legislation introducing suspected terrorists’ designation
and listing, assets freezing, and de-listing procedures in
accordance with UNSCRs 1267 and 1373. Given the absence of
specific legislation governing the freezing of terrorist assets,
Greece used an administrative procedure to freeze assets of
suspected terrorists designated domestically or upon request of
foreign authorities. Though Greek authorities worked to improve
the effectiveness of the Greek Financial Intelligence Unit,
additional work remained to meet international standards.

Regional and International Cooperation: Greece participated in
regional information exchange and seminars through such bodies
as the OSCE, the Southeast European Cooperative Initiative
regional Center for Combating Trans-Border Crime, and the
Organization of Black Sea Economic Cooperation. Greece is a
member of the UN Counterterrorism Committee.

Countering Radicalization and Violent Extremism: Municipal
governments in Athens established immigrant councils to foster
dialogue on issues such as discrimination, social benefits for
immigrants, legalization, employment, and security. Police officials
met with representatives of the different immigrant communities to
discuss ways to address discrimination and incidents of police
abuse.

____________________________________________________

Links:

Worldwide AML Legislation (International Bar Association)

Foreas Arthrou 7 N.2331/95 Hellenic Anti-Money Laundering and
Anti-Terrorism Financing Commission (HAMLC)
Tables & Rankings
Are there Sanctions in force against it? (UN/EU/US)
N
?
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
White
?
Is it on EU 'white' list of equivalent jurisdictions?
EU
?
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)
PC
?
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)
80 (out of
183)
78 (out of
178)
?
Ease of doing business (World Bank)
100 (out of
183)
109 (out
of 183)
?
FATF 40 + 9 recommendations
Mutual Evaluation Report: 2007
Further Tables
C
L
P
N
N/A
    C  -  Fully Compliant ,   
    L  -  Largely Compliant,    
    P  -  Partially Compliant    
    N  -  Non-Compliant
2
10
23
13
1
Legal Systems
 
1. Money Laundering Offence
P
 
14. Protection & no tipping-off
C
2. ML offence – mental element and
corporate liability
P
 
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
P
 
17. Sanctions
P
5. Customer due diligence
P
 
18. Shell banks
L
6. Politically exposed persons
N
 
19. Other forms of reporting
N
7. Correspondent banking
L
 
20. Other NFBP & secure
transaction techniques
L
8. New technologies & non
face-to-face business
P
 
21. Special attention for
higher risk countries
N
9. Third parties and introducers
P
 
22. Foreign branches &
subsidiaries
P
10. Record keeping
L
 
23. Regulation, supervision
and monitoring
P
11. Unusual transactions
P
 
24. DNFBP - regulation,
supervision and monitoring
N
12. Designated Non-Financial
Businesses and Professions – R.5,
6, 8-11
N
 
25. Guidelines & Feedback
N
13. Suspicious transaction reporting
P
     
Institutional and other
measures
 
26. The FIU
N
 
31. National co-operation
P
27. Law enforcement authorities
L
 
32. Statistics
N
28. Powers of competent authorities
C
 
33. Legal persons – beneficial
owners
N
29. Supervisors
P
 
34. Legal arrangements –
beneficial owners
N/A
30. Resources, integrity and training
N
 
 
 
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
P
Nine Special
Recommendations
 
SR.I Implement UN instruments
P
 
SR VI AML requirements for
money/value transfer services
P
SR.II Criminalise terrorist financing
P
 
SR VII Wire transfer rules
P
SR.III Freeze and confiscate terrorist
assets
P
 
SR.VIII Non profit
organisations
N
SR.IV Suspicious transaction
reporting
P
 
SR.IX Cross Border
Declaration & Disclosure
N
SR.V International co-operation
L
 
 
 
*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.
GREECE
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
The FATF has approved and published the follow-up report for Greece.  
Greece was originally placed in the regular follow-up process as a result
of partially compliant and non compliant ratings in certain of the Core
and Key Recommendations in its mutual evaluation report of June 2007.
Greece has taken sufficient action to address these deficiencies and
has therefore been taken off the regular follow-up process. Henceforth
Greece will report back to the Plenary on any further improvements to its
AML/CFT regime on a biennial basis.

Click here to view Follow-Up Report to the Mutual Evaluation of Greece
AML News/Updates

Nov 1, 2011  -  Greece has taken sufficient action to address these
deficiencies and has therefore been taken off the regular follow-up
process.
Last Updated:   16 April 2012