___________________________________________________
US State Dept Narcotics Report 2011 (introduction):
No report available
_________________________________________________________
US State Dept Trafficking in Persons Report 2011 (introduction):
(Tier 2 Watch List)
Syria is principally a destination country for women and children
subjected to forced labor or sex trafficking. Thousands of women – the
majority from Indonesia, the Philippines, Somalia, and Ethiopia – are
recruited by employment agencies to work in Syria as domestic servants,
but are subsequently subjected to conditions of forced labor by their
employers. Some of these women are confined to the private residences
in which they work, and most have their passports confiscated, contrary
to Syrian law, by their employer or the labor recruitment agency.
Contracts signed in the employee’s country of origin are often changed
upon arrival in Syria, contributing to the employee’s vulnerability to
forced labor. The Government of Ethiopia’s ban on its citizens accepting
employment in Syria has not stopped the flow of workers into the
country. Some Iraqi refugees reportedly contract their daughters to work
as maids in Syrian households, where they may be subsequently
expected to perform sexual acts and are vulnerable to forced labor.
Women from Eastern Europe – particularly Ukraine – Somalia, and
Morocco are recruited legally as cabaret dancers in Syria; some
“entertainers” are subsequently forced into prostitution after their
employers confiscate their passports and confine them to their hotels.
Due to the economic desperation of Syria’s large Iraqi refugee
population, some women and girls suffer trafficking at the hands of their
families or by criminal gangs; victims are placed to work in nightclubs, for
temporary “marriages” to men for the sole purpose of prostitution, or to
be sold to pimps who rent them out for longer periods of time. Some Iraqi
parents have reportedly abandoned their daughters at the Iraqi side of
the border with Syria with the expectation that traffickers will arrange for
them forged documents to enter Syria and employment in a nightclub. In
other instances, refugees’ children remain in Syria while their parents
leave the country in search of improved economic circumstances,
leaving the children vulnerable to trafficking. Iraqi women deported from
Syria on prostitution charges are vulnerable to re-trafficking by criminal
gangs operating along the border. Syria is a transit country for Iraqi
women and girls, as well as Southeast Asians and East Africans,
subjected to conditions of forced prostitution in Europe, Saudi Arabia,
Kuwait, United Arab Emirates, and Lebanon.
Anecdotal evidence suggests that some economically desperate Syrian
children are subjected to conditions of forced labor within the country,
particularly by organized street begging rings. Some Syrian women in
Lebanon may be forced to engage in street prostitution and small
numbers of Syrian girls are reportedly brought to Lebanon for the
purpose of prostitution, including through the guise of early marriage.
Small numbers of Syrian adults are reportedly subjected to forced labor
as low-skilled workers in Qatar and Kuwait.
The Government of Syria does not fully comply with the minimum
standards for the elimination of trafficking; however, it is making
significant efforts to do so. During the year, the government made
modest anti-trafficking efforts, with the Ministry of Interior launching a
200-person anti-trafficking directorate and the government hosting an
international conference on human trafficking. Despite these efforts, the
government did not demonstrate evidence of increasing efforts to
investigate and punish trafficking offenses, inform the public about the
practice of human trafficking, or provide much needed anti-trafficking
training to law enforcement and social welfare officials over the past
year. Therefore, Syria is placed on Tier 2 Watch List. The government
did not respond to requests to provide information on its victim
protection efforts for inclusion in this report.
For full report click here
_________________________________________________________
US State Dept Terrorism Report 2009
Syria is a signatory to nine of the 13 international conventions and
protocols relating to terrorism. While Syrian officials have publicly
condemned international terrorism, they continue to insist there is a
distinction between terrorist attacks and attacks undertaken by “national
liberation movements” engaged in legitimate armed resistance, including
Palestinian groups, Lebanese Hizballah, and members of the Iraqi
opposition. The United States does not agree with this characterization
and has designated a number of these groups as Foreign Terrorist
Organizations. During the reporting period, the United States raised
concerns about Syria’s support of these groups directly with the Syrian
government.
Designated in 1979 as a State Sponsor of Terrorism, Syria continued to
provide safe-haven as well as political and other support to a number of
designated Palestinian terrorist groups, including HAMAS, Palestinian
Islamic Jihad (PIJ), and the Popular Front for the Liberation of Palestine-
General Command (PFLP-GC). Several of these terrorist groups have
claimed responsibility for terrorist acts in the past, but none over the
past year. The operational leadership of many of these groups is
headquartered or sheltered in Damascus, including Khaled Meshaal of
HAMAS, Ramadan Shallah of PIJ, and Ahmed Jibril of PFLP-GC. The
Syrian government provided Meshaal with security escorts for his
motorcades and allowed him to travel freely around Damascus,
attending numerous public events such as national day celebrations for
Arab states. Though the Syrian government claimed periodically that it
used its influence to restrain the activities of Palestinian groups, it
allowed conferences organized by HAMAS to take place over the course
of the year. In addition, the Syrian government has made no attempt to
restrict the operation, travel, or movement of these groups’ leaders or
members. Syria allows terrorist groups resident in its territory to receive
and ship goods, including weapons, in and out of the country.
Additionally, the Syrian government provided diplomatic, political and
material support to Hizballah in Lebanon and allowed Iran to supply this
organization with weapons. Weapons flow from Iran through Syria, and
directly from Syria, to Hizballah despite UN Security Council resolution
1701 of 2006, which imposes an arms embargo on Lebanon except with
the consent of the Lebanese government. Indeed, Hizballah claims to
have a larger arsenal today than it did in 2006. Underscoring links
between the Syrian government and Hizballah, Israeli naval commandos
intercepted a large cache of arms on November 3 on its way from Iran to
Hizballah by way of the Syrian port of Latakia. The arms shipment, which
was found amidst civilian cargo on the Antiguan-flagged ship MV
Francop, weighed over 500 tons. While the Syrian government denied
involvement in the shipment, Israeli officials stressed that the incident
illustrates Syria’s continued efforts to fight a proxy war with Israel through
terrorist groups like Hizballah The last attack across the internationally-
recognized Israeli line of withdrawal (a.k.a. the Blue Line) occurred in
2006. In the same year, a terrorist attack on the U.S. Embassy in
Damascus was defeated by Syrian security forces.
Syria has maintained its ties with its strategic ally, and fellow state
sponsor of terrorism, Iran. In August, President al-Asad visited Tehran.
On December 3, the Syrian president met the Iranian National Security
Advisor Said Jalili in Damascus. On December 8, Iranian Defense
Minister Ahmed Vahidi began a three-day visit to Syria, where he met
with political and military leaders. Vahidi and his Syrian counterpart
announced a Syrian-Iranian defense cooperation agreement on
December 11. Frequent working-level visits between Iranian and Syrian
officials took place regularly throughout 2009. Syria also allowed leaders
of HAMAS and other Palestinian groups to visit Tehran. Al-Asad
continued to be a staunch defender of Iran’s policies, including Iran’s
nuclear ambitions.
The number of foreign fighters from extremist groups, including those
affiliated with Al Qaeda in Iraq (AQI), transiting through Syrian territory
into Iraq has decreased significantly from its peak flows in 2005-2007.
The existence of foreign fighter facilitation networks in Syria, however,
remains troubling. Bombings in Iraq in 2009 underscore the threat these
networks continue to pose, but the United States recognizes Syrian
efforts to decrease foreign fighter travel into Iraqi during the reporting
period. In 2009, Syria increased border monitoring activities, instituted
tighter screening practices on military-age Arab males entering its
borders, and agreed to participate with the U.S. and Iraqi governments
in a trilateral border security assessment of the Syrian side of the Syrian-
Iraqi border. Although preparatory meetings were held, the actual border
assessment did not occur after the Iraqi government withdrew its support
in August 2009. The Syrians have indicated a willingness to establish a
border security mechanism if future Iraqi governments are supportive.
While Syria has long provided sanctuary and political support for certain
former Iraqi regime elements (FRE), Damascus denied supporting
terrorist attacks and urged Baghdad to include the FRE in the Iraqi
political process. In 2008, the United States designated several Iraqis
and Iraqi-owned entities residing in Syria under Executive Order 13438
for providing financial, material, and technical support for acts of
violence that threatened the peace and stability of Iraq, including Mish’
an Al-Jaburi and his satellite television channel al-Rai. Iraqi government
officials criticized al-Rai for serving as a “platform for terrorists.”
Additionally, the United States designated one Syria-based individual in
2007 under E.O. 13224 for providing financial and material support to
AQI and six others under E.O. 13315 as FRE or family members of FRE,
some of whom had provided financial assistance to the Iraqi insurgency.
Syria’s financial sector remains vulnerable to terrorist financing. An
estimated 70 percent of all business transactions are conducted in cash
and as many as 80 percent of all Syrians do not use formal banking
services. Despite Syrian legislation requiring money-changers to be
licensed by the end of 2007, many continued to operate illegally in Syria’
s vast black market, which is believed to be as large as Syria’s formal
economy. Regional “hawala” networks remained intertwined with
smuggling and trade-based money laundering – facilitated by corrupt
customs and immigration officials – raising significant concerns that the
Syrian government and business elites could be complicit in terrorist
financing schemes.
_________________________________________________________
AML Updates / News
March 26. 2012 - Notice for the attention of the persons and entities to
which restrictive measures provided for in Council Decision
2011/782/CFSP, as implemented by Council Implementing Decision
2012/172/CFSP, and Council Regulation (EU) No 36/2012, as
implemented by Council Implementing Regulation (EU) No 266/2012
concerning restrictive measures in view of the situation in Syria apply
Read More
February 28, 2012 - EU Council agreed further restrictive measures
against Syria in its Council Decision 2012/122/CFSP (“the Decision”) of
27 February 2012
Read Regulation
February 24, 2012 - OFAC has issued General License 15 related to
Syria to authorize transactions in connection with patent, trademark,
copyright, or other intellectual property protection that would otherwise
be prohibited by Executive Order 13582.
Read General Licence
January 25, 2012 - EU Council Implement Regulation (EU) No 55/2012
in respect of the restrictive measures directed by the Council of the
European Union in view of the situation in Syria
Read Regulation
January 19, 2012 - The EU has imposed Regulation(EU) No 36/2012
of 18 January 2012 concerning restrictive measures in view of the
situation in Syria and repealing Regulation (EU) No 442/2011
Read Regulation
December 2, 2011 - EU Council implement further sanctions on Syria -
Regulation (EU) No 1244/2011
Read regulation
November 28, 2011 - The Arab League (comprising 22 Arab member
states), of which this country is a member, has approved imposing
sanctions on Syria. These include: -
* Cutting off transactions with the Syrian central bank
* Halting funding by Arab governments for projects in Syria
* A ban on senior Syrian officials travelling to other Arab countries
* A freeze on assets related to President Bashar al-Assad's government
The declaration also calls on Arab central banks to monitor transfers to
Syria, with the exception of remittances from Syrians abroad.
For further information, click here
November 14, 2011 - EU Council Regulation (EU) No 1150/2011 of
14 November 2011 amending Regulation (EU) No 442/2011
concerning restrictive measures in view of the situation in Syria
Read Regulation
September 27, 2011 - USA (OFAC) issues General Licence 12 re
authorize third-country diplomatic and consular funds transfers
Read Licence
September 3, 2011 - EU bans import of Syrian Oil
Read press release
August 11, 2011 - FinCEN issues advisory to alert U.S. financial
institutions of information on the Commercial Bank of Syria's continued
involvement in illicit financial activities.
View Advisory
May 18, 2011 - the US imposed an Executive Order Blocking Property
of Certain Persons with Respect to Human Rights Abuses in Syria.
For further information:
http://www.treasury.gov/resource-center/sanctions/OFAC-
Enforcement/Pages/20110518.aspx
Links:
Worldwide AML Legislation (International Bar Association)
US State Dept Narcotics Report 2011 (introduction):
No report available
_________________________________________________________
US State Dept Trafficking in Persons Report 2011 (introduction):
(Tier 2 Watch List)
Syria is principally a destination country for women and children
subjected to forced labor or sex trafficking. Thousands of women – the
majority from Indonesia, the Philippines, Somalia, and Ethiopia – are
recruited by employment agencies to work in Syria as domestic servants,
but are subsequently subjected to conditions of forced labor by their
employers. Some of these women are confined to the private residences
in which they work, and most have their passports confiscated, contrary
to Syrian law, by their employer or the labor recruitment agency.
Contracts signed in the employee’s country of origin are often changed
upon arrival in Syria, contributing to the employee’s vulnerability to
forced labor. The Government of Ethiopia’s ban on its citizens accepting
employment in Syria has not stopped the flow of workers into the
country. Some Iraqi refugees reportedly contract their daughters to work
as maids in Syrian households, where they may be subsequently
expected to perform sexual acts and are vulnerable to forced labor.
Women from Eastern Europe – particularly Ukraine – Somalia, and
Morocco are recruited legally as cabaret dancers in Syria; some
“entertainers” are subsequently forced into prostitution after their
employers confiscate their passports and confine them to their hotels.
Due to the economic desperation of Syria’s large Iraqi refugee
population, some women and girls suffer trafficking at the hands of their
families or by criminal gangs; victims are placed to work in nightclubs, for
temporary “marriages” to men for the sole purpose of prostitution, or to
be sold to pimps who rent them out for longer periods of time. Some Iraqi
parents have reportedly abandoned their daughters at the Iraqi side of
the border with Syria with the expectation that traffickers will arrange for
them forged documents to enter Syria and employment in a nightclub. In
other instances, refugees’ children remain in Syria while their parents
leave the country in search of improved economic circumstances,
leaving the children vulnerable to trafficking. Iraqi women deported from
Syria on prostitution charges are vulnerable to re-trafficking by criminal
gangs operating along the border. Syria is a transit country for Iraqi
women and girls, as well as Southeast Asians and East Africans,
subjected to conditions of forced prostitution in Europe, Saudi Arabia,
Kuwait, United Arab Emirates, and Lebanon.
Anecdotal evidence suggests that some economically desperate Syrian
children are subjected to conditions of forced labor within the country,
particularly by organized street begging rings. Some Syrian women in
Lebanon may be forced to engage in street prostitution and small
numbers of Syrian girls are reportedly brought to Lebanon for the
purpose of prostitution, including through the guise of early marriage.
Small numbers of Syrian adults are reportedly subjected to forced labor
as low-skilled workers in Qatar and Kuwait.
The Government of Syria does not fully comply with the minimum
standards for the elimination of trafficking; however, it is making
significant efforts to do so. During the year, the government made
modest anti-trafficking efforts, with the Ministry of Interior launching a
200-person anti-trafficking directorate and the government hosting an
international conference on human trafficking. Despite these efforts, the
government did not demonstrate evidence of increasing efforts to
investigate and punish trafficking offenses, inform the public about the
practice of human trafficking, or provide much needed anti-trafficking
training to law enforcement and social welfare officials over the past
year. Therefore, Syria is placed on Tier 2 Watch List. The government
did not respond to requests to provide information on its victim
protection efforts for inclusion in this report.
For full report click here
_________________________________________________________
US State Dept Terrorism Report 2009
Syria is a signatory to nine of the 13 international conventions and
protocols relating to terrorism. While Syrian officials have publicly
condemned international terrorism, they continue to insist there is a
distinction between terrorist attacks and attacks undertaken by “national
liberation movements” engaged in legitimate armed resistance, including
Palestinian groups, Lebanese Hizballah, and members of the Iraqi
opposition. The United States does not agree with this characterization
and has designated a number of these groups as Foreign Terrorist
Organizations. During the reporting period, the United States raised
concerns about Syria’s support of these groups directly with the Syrian
government.
Designated in 1979 as a State Sponsor of Terrorism, Syria continued to
provide safe-haven as well as political and other support to a number of
designated Palestinian terrorist groups, including HAMAS, Palestinian
Islamic Jihad (PIJ), and the Popular Front for the Liberation of Palestine-
General Command (PFLP-GC). Several of these terrorist groups have
claimed responsibility for terrorist acts in the past, but none over the
past year. The operational leadership of many of these groups is
headquartered or sheltered in Damascus, including Khaled Meshaal of
HAMAS, Ramadan Shallah of PIJ, and Ahmed Jibril of PFLP-GC. The
Syrian government provided Meshaal with security escorts for his
motorcades and allowed him to travel freely around Damascus,
attending numerous public events such as national day celebrations for
Arab states. Though the Syrian government claimed periodically that it
used its influence to restrain the activities of Palestinian groups, it
allowed conferences organized by HAMAS to take place over the course
of the year. In addition, the Syrian government has made no attempt to
restrict the operation, travel, or movement of these groups’ leaders or
members. Syria allows terrorist groups resident in its territory to receive
and ship goods, including weapons, in and out of the country.
Additionally, the Syrian government provided diplomatic, political and
material support to Hizballah in Lebanon and allowed Iran to supply this
organization with weapons. Weapons flow from Iran through Syria, and
directly from Syria, to Hizballah despite UN Security Council resolution
1701 of 2006, which imposes an arms embargo on Lebanon except with
the consent of the Lebanese government. Indeed, Hizballah claims to
have a larger arsenal today than it did in 2006. Underscoring links
between the Syrian government and Hizballah, Israeli naval commandos
intercepted a large cache of arms on November 3 on its way from Iran to
Hizballah by way of the Syrian port of Latakia. The arms shipment, which
was found amidst civilian cargo on the Antiguan-flagged ship MV
Francop, weighed over 500 tons. While the Syrian government denied
involvement in the shipment, Israeli officials stressed that the incident
illustrates Syria’s continued efforts to fight a proxy war with Israel through
terrorist groups like Hizballah The last attack across the internationally-
recognized Israeli line of withdrawal (a.k.a. the Blue Line) occurred in
2006. In the same year, a terrorist attack on the U.S. Embassy in
Damascus was defeated by Syrian security forces.
Syria has maintained its ties with its strategic ally, and fellow state
sponsor of terrorism, Iran. In August, President al-Asad visited Tehran.
On December 3, the Syrian president met the Iranian National Security
Advisor Said Jalili in Damascus. On December 8, Iranian Defense
Minister Ahmed Vahidi began a three-day visit to Syria, where he met
with political and military leaders. Vahidi and his Syrian counterpart
announced a Syrian-Iranian defense cooperation agreement on
December 11. Frequent working-level visits between Iranian and Syrian
officials took place regularly throughout 2009. Syria also allowed leaders
of HAMAS and other Palestinian groups to visit Tehran. Al-Asad
continued to be a staunch defender of Iran’s policies, including Iran’s
nuclear ambitions.
The number of foreign fighters from extremist groups, including those
affiliated with Al Qaeda in Iraq (AQI), transiting through Syrian territory
into Iraq has decreased significantly from its peak flows in 2005-2007.
The existence of foreign fighter facilitation networks in Syria, however,
remains troubling. Bombings in Iraq in 2009 underscore the threat these
networks continue to pose, but the United States recognizes Syrian
efforts to decrease foreign fighter travel into Iraqi during the reporting
period. In 2009, Syria increased border monitoring activities, instituted
tighter screening practices on military-age Arab males entering its
borders, and agreed to participate with the U.S. and Iraqi governments
in a trilateral border security assessment of the Syrian side of the Syrian-
Iraqi border. Although preparatory meetings were held, the actual border
assessment did not occur after the Iraqi government withdrew its support
in August 2009. The Syrians have indicated a willingness to establish a
border security mechanism if future Iraqi governments are supportive.
While Syria has long provided sanctuary and political support for certain
former Iraqi regime elements (FRE), Damascus denied supporting
terrorist attacks and urged Baghdad to include the FRE in the Iraqi
political process. In 2008, the United States designated several Iraqis
and Iraqi-owned entities residing in Syria under Executive Order 13438
for providing financial, material, and technical support for acts of
violence that threatened the peace and stability of Iraq, including Mish’
an Al-Jaburi and his satellite television channel al-Rai. Iraqi government
officials criticized al-Rai for serving as a “platform for terrorists.”
Additionally, the United States designated one Syria-based individual in
2007 under E.O. 13224 for providing financial and material support to
AQI and six others under E.O. 13315 as FRE or family members of FRE,
some of whom had provided financial assistance to the Iraqi insurgency.
Syria’s financial sector remains vulnerable to terrorist financing. An
estimated 70 percent of all business transactions are conducted in cash
and as many as 80 percent of all Syrians do not use formal banking
services. Despite Syrian legislation requiring money-changers to be
licensed by the end of 2007, many continued to operate illegally in Syria’
s vast black market, which is believed to be as large as Syria’s formal
economy. Regional “hawala” networks remained intertwined with
smuggling and trade-based money laundering – facilitated by corrupt
customs and immigration officials – raising significant concerns that the
Syrian government and business elites could be complicit in terrorist
financing schemes.
_________________________________________________________
AML Updates / News
March 26. 2012 - Notice for the attention of the persons and entities to
which restrictive measures provided for in Council Decision
2011/782/CFSP, as implemented by Council Implementing Decision
2012/172/CFSP, and Council Regulation (EU) No 36/2012, as
implemented by Council Implementing Regulation (EU) No 266/2012
concerning restrictive measures in view of the situation in Syria apply
Read More
February 28, 2012 - EU Council agreed further restrictive measures
against Syria in its Council Decision 2012/122/CFSP (“the Decision”) of
27 February 2012
Read Regulation
February 24, 2012 - OFAC has issued General License 15 related to
Syria to authorize transactions in connection with patent, trademark,
copyright, or other intellectual property protection that would otherwise
be prohibited by Executive Order 13582.
Read General Licence
January 25, 2012 - EU Council Implement Regulation (EU) No 55/2012
in respect of the restrictive measures directed by the Council of the
European Union in view of the situation in Syria
Read Regulation
January 19, 2012 - The EU has imposed Regulation(EU) No 36/2012
of 18 January 2012 concerning restrictive measures in view of the
situation in Syria and repealing Regulation (EU) No 442/2011
Read Regulation
December 2, 2011 - EU Council implement further sanctions on Syria -
Regulation (EU) No 1244/2011
Read regulation
November 28, 2011 - The Arab League (comprising 22 Arab member
states), of which this country is a member, has approved imposing
sanctions on Syria. These include: -
* Cutting off transactions with the Syrian central bank
* Halting funding by Arab governments for projects in Syria
* A ban on senior Syrian officials travelling to other Arab countries
* A freeze on assets related to President Bashar al-Assad's government
The declaration also calls on Arab central banks to monitor transfers to
Syria, with the exception of remittances from Syrians abroad.
For further information, click here
November 14, 2011 - EU Council Regulation (EU) No 1150/2011 of
14 November 2011 amending Regulation (EU) No 442/2011
concerning restrictive measures in view of the situation in Syria
Read Regulation
September 27, 2011 - USA (OFAC) issues General Licence 12 re
authorize third-country diplomatic and consular funds transfers
Read Licence
September 3, 2011 - EU bans import of Syrian Oil
Read press release
August 11, 2011 - FinCEN issues advisory to alert U.S. financial
institutions of information on the Commercial Bank of Syria's continued
involvement in illicit financial activities.
View Advisory
May 18, 2011 - the US imposed an Executive Order Blocking Property
of Certain Persons with Respect to Human Rights Abuses in Syria.
For further information:
http://www.treasury.gov/resource-center/sanctions/OFAC-
Enforcement/Pages/20110518.aspx
Links:
Worldwide AML Legislation (International Bar Association)
|
|
FATF Statement re AML Strategic Deficiencies:
Date: 16 February 2012
Syria has taken significant steps towards improving its AML/CFT
regime, including by improving the legal arrangements for
freezing terrorist assets. However, despite Syria’s high-level
political commitment to work with the FATF and MENAFATF,
further engagement with Syria is needed to clarify whether the
remaining deficiencies have been addressed, including by: (1)
implementing adequate procedures for identifying and freezing
terrorist assets (Special Recommendation III); (2) ensuring that
financial institutions are aware of and comply with their obligations
to file suspicious transaction reports in relation to ML and FT
(Recommendation 13 and Special Recommendation IV); and (3)
ensuring that appropriate laws and procedures are in place to
provide mutual legal assistance (Recommendations 36-38,
Special Recommendation V). The FATF encourages Syria to
demonstrate that its remaining deficiencies have been addressed
to enable the FATF to properly evaluate Syria’s progress.
____________________________________________________
Sanctions:
May 2, 2012 - US President signs an Executive Order (E.O.),
“Prohibiting Certain Transactions with and Suspending Entry into
the United States of Foreign Sanctions Evaders with Respect to
Iran and Syria,” providing the U.S. Treasury Department with a
new authority to tighten further the U.S. sanctions on Iran and
Syria.
Read Executive Order
April 27, 2012 - The Office of Foreign Assets Control has issued
General License 4A, which authorizes the exports or reexports to
Syria of items licensed or otherwise authorized by the Department
of Commerce and of exports and reexports of certain services.
General License 4A replaces and supersedes General License 4,
dated August 18, 2011.
Read License
April 23, 2012 - Executive order blocking the property and
suspending entry into the United States of certain persons with
respect to grave human rights abuses by the governments of Iran
and Syria via information technology
Read Executive Order
March 26. 2012 - Notice for the attention of the persons and
entities to which restrictive measures provided for in Council
Decision 2011/782/CFSP, as implemented by Council
Implementing Decision 2012/172/CFSP, and Council Regulation
(EU) No 36/2012, as implemented by Council Implementing
Regulation (EU) No 266/2012 concerning restrictive measures in
view of the situation in Syria apply
Read More
28 February 2012 - EU Council agreed further restrictive
measures against Syria in its Council Decision 2012/122/CFSP
(“the Decision”) of 27 February 2012
Read Regulation
February 24, 2012 - OFAC has issued General License 15
related to Syria to authorize transactions in connection with
patent, trademark, copyright, or other intellectual property
protection that would otherwise be prohibited by Executive Order
13582.
Read General Licence
January 25, 2012 - EU Council Implement Regulation (EU) No
55/2012 in respect of the restrictive measures directed by the
Council of the European Union in view of the situation in Syria
Read Regulation
January 19, 2012 - The EU has imposed Regulation(EU) No
36/2012 of 18 January 2012 concerning restrictive measures in
view of the situation in Syria and repealing Regulation (EU) No
442/2011
Read Regulation
December 2, 2011 - EU Council implement further sanctions on
Syria - Regulation (EU) No 1244/2011
Read regulation
November 28, 2011 - The Arab League (comprising 22 Arab
member states), of which this country is a member, has approved
imposing sanctions on Syria. These include: -
* Cutting off transactions with the Syrian central bank
* Halting funding by Arab governments for projects in Syria
* A ban on senior Syrian officials travelling to other Arab countries
* A freeze on assets related to President Bashar al-Assad's
government
The declaration also calls on Arab central banks to monitor
transfers to Syria, with the exception of remittances from Syrians
abroad.
Click here for further information
Implementation of COUNCIL REGULATION (EU) No 1150/2011
of 14 November 2011 amending Regulation (EU) No
442/2011 concerning restrictive measures in view of the
situation in Syria
Read Regulation
Council Implementing Regulation (EU) No 1151/2011 of 14
November 2011 implementing Regulation (EU) No 442/2011
concerning restrictive measures in view of the situation in Syria.
Read Regulation
U.S. depository institutions, U.S. registered brokers or dealers in
securities, and U.S. registered money transmitters are authorized
to process funds transfers for the operating expenses or other
official business of third-country diplomatic or consular missions in
Syria, provided that the transfer is not by, to, or through the
Govemment of Syria or any other person whose property and
interests in property are blocked pursuant to previous Executive
Orders
Click here to read General Licence 12
On 18th May, 2011, the US imposed an Executive Order Blocking
Property of Certain Persons with Respect to Human Rights
Abuses in Syria.
This now stands with other types of sanctions that the U.S.
government has imposed against Syria. The most comprehensive
sanction, called the Syria Accountability Act (SAA) of 2004,
prohibits the export of most goods containing more than 10% U.S.-
manufactured component parts to Syria. Another sanction,
resulting from the USA Patriot Act, was levied specifically against
the Commercial Bank of Syria in 2006. The third type of sanction
contains many Executive Orders from the President that
specifically deny certain Syrian citizens and entities access to the
U.S. financial system due to their participation in proliferation of
weapons of mass destruction, association with Al Qaida, the
Taliban or Osama bin Laden; or destabilizing activities in Iraq and
Lebanon.
For further information: -
http://www.treasury.gov/resource-
center/sanctions/Programs/pages/syria.aspx
On 23rd May, 2011, the EU strengthened Restrictive Measures
already in place to include President Bashar A-Assad and certain
members of his regime. For further information, please visit the
following link: -
http://www.consilium.europa.
eu/uedocs/cms_Data/docs/pressdata/EN/foraff/122157.pdf
For further information on EU restrictive measures, please visit
the following link: -
http://ec.europa.
eu/external_relations/cfsp/sanctions/docs/measures_en.pdf
The Arab League (comprising 22 Arab member states), of which
this country is a member, has boycotted Israel in a systematic
effort to isolate Israel economically in support of the Palestinians,
however, the implementation of the boycott has varied over time
among member states..
There are three tiers to the boycott. The primary boycott prohibits
the importation of Israeli-origin goods and services into boycotting
countries. The secondary boycott prohibits individuals, as well as
private and public sector firms and organizations, in member
countries from engaging in business with any entity that does
business in Israel. The Arab League maintains a blacklist of such
firms. The tertiary boycott prohibits any
entity in a member country from doing business with a company or
individual that has business dealings with U.S. or other firms on
the Arab League blacklist.
____________________________________________________
Offshore Jurisdiction Blacklists:
Information unavailable.
____________________________________________________
US State Department Money Laundering Report - 2011
Syria is not an important regional or offshore financial center, due
primarily to its still underdeveloped private banking sector and the
fact that the Syrian pound is not a fully convertible currency.
Despite rapid growth in the banking sector, industry experts
estimate only 20 percent of Syria’s population of nearly 22 million
people actually uses banking services. Consequently, some 60
percent of all business transactions are still conducted in cash.
Estimates of the volume of business conducted in the black
market by Syrian moneychangers range between $15 and $70
million per day. Additionally, there continue to be significant
money laundering and terrorist financing vulnerabilities in Syria’s
banking and non-bank financial sectors due to either a lack of
necessary legislation or poor government enforcement of existing
laws. Syria’s black market moneychangers are not adequately
regulated, and the country’s borders remain porous. Regional
hawala networks, intertwined with smuggling and trade-based
money laundering, raise significant concerns, including
involvement in the financing of terrorism. The most obvious
indigenous money laundering threat involves Syria’s political and
business elite, whose corruption and extra-legal activities continue
unabated.
There are eight public free trade zones (FTZs) in Syria and five
additional free zones are planned in Damascus, Homs, Dayr ez-
Zawr, Idleb, and the port of Tartous. In recent years, both China
and Iran announced plans to build FTZs in Syria, although Iran
later dropped this idea in favor of pursuing a free trade
agreement with Syria. China’s free zone in Adra was officially
inaugurated in July 2008; thirteen businesses have been
established in Adra to-date. The volume of goods entering the
FTZs is estimated to be in the billions of dollars and is growing,
especially with increasing demand for automobiles and automotive
parts, which enter the zones free of customs tariffs before being
imported into Syria. While all industries and financial institutions in
the FTZs must be registered with the General Organization for
Free Zones, part of the Ministry of Economy and Trade, the
Syrian General Directorate of Customs continues to lack strong
procedures to check country of origin certification or the
resources to adequately monitor goods that enter Syria through
the zones. There are also continuing reports of Syrians using the
FTZs to import arms and other goods into Syria in violation of
USG sanctions under the Syrian Accountability Act, and a number
of United Nations Security Council Resolutions.
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: List approach
Legal persons covered: criminally: YES civilly: YES
CRIMINALIZATION OF TERRORIST FINANCING:
Ability to freeze terrorist assets without delay: NO
UN lists of designated terrorists or terrorist entities distributed to
financial institutions: YES
KNOW-YOUR-CUSTOMER RULES:
Covered entities: Banks; money exchanges and remitters; issuers
of payment instruments such as credit cards, payment cards,
travelers checks, and ATM cards; investment funds and their
managers; financial brokerages and financial leasing
corporations; insurance companies; real-estate brokers and
agents; dealers of high-value goods, such as jewelry, precious
stones, gold, and antiquities; lawyers; and accountants
Enhanced due diligence procedures for PEPs: Foreign: NO
Domestic: NO
SUSPICIOUS TRANSACTION REPORTING REQUIREMENTS:\
Covered entities: Banks; money exchanges and remitters; issuers
of payment instruments such as credit cards, payment cards,
travelers checks, and ATM cards; investment funds and their
managers; financial brokerages and financial leasing
corporations; insurance companies; real-estate brokers and
agents; dealers of high-value goods, such as jewelry, precious
stones, gold, and antiquities; lawyers; and accountants
Number of STRs received and time frame: 144 from January to
November 2010
Number of CTRs received and time frame: Not available
MONEY LAUNDERING CRIMINAL
PROSECUTIONS/CONVICTIONS:
Prosecutions: Not available
Convictions: 0
Assets forfeited: criminally: Not available civilly: Not available
RECORDS EXCHANGE MECHANISM:
With U.S.: YES
With other governments/jurisdictions: YES
Syria is a member of the Middle East and North Africa Financial
Action Task Force (MENAFATF), a Financial Action Task Force-
style regional body. Syria’s most recent mutual evaluation can be
found at: http://www.menafatf.
org/images/UploadFiles/MutualEvaluationReportofSyria.pdf
ENFORCEMENT AND IMPLEMENTATION ISSUES AND
COMMENTS:
The United States has designated Syria as a State Sponsor of
Terrorism.
In May 2004, the U.S. Department of Treasury found the
Commercial Bank of Syria (CBS), along with its subsidiary, the
Syrian Lebanese Commercial Bank, to be a financial institution of
“primary money laundering concern,” pursuant to Section 311 of
the USA PATRIOT Act. This finding resulted from information that
CBS had been used by terrorists or persons associated with
terrorist organizations as a conduit for the laundering of proceeds
generated from the illicit sale of Iraqi oil, and because of
continued concerns that CBS was vulnerable to exploitation by
criminal and/or terrorist enterprises. In April 2006, Treasury
promulgated a final rule, based on the 2004 finding and proposed
rule-making, prohibiting U.S. financial institutions from maintaining
or opening correspondent or payable-through accounts with CBS
or its Syrian Lebanese Commercial Bank subsidiary.
Most Syrian judges are not yet familiar with the evidentiary
requirements of the anti-money laundering law. Furthermore, the
slow pace of the Syrian legal system and political sensitivities
delay quick adjudication of these issues. The lack of expertise,
further undermined by a lack of political will, continues to impede
effective implementations of existing AML/CFT regulations.
Although Decree 33 provides the Central Bank with the legal basis
to combat money laundering, most Syrians still do not maintain
bank accounts or use checks, credit cards, or ATM machines.
The Syrian economy remains primarily cash-based, and Syrians
use moneychangers, some of whom also act as hawaladars, for
many financial transactions. As a step to enhancing oversight of
moneychangers, in 2006 a law was passed to cover
moneychangers; however, they remain largely unregulated.
In addition to cash smuggling, there is also a high rate of
commodity smuggling out of Syria. It has been reported that some
smuggling is occurring with the knowledge of, or perhaps even
under the authority of, the Syrian security services. The General
Directorate of Customs lacks the necessary staff and financial
resources to effectively handle the problem of smuggling. While
customs has started to enact some limited reforms, including the
computerization of border outposts to interface with other
government agencies, problems of information-sharing remain.
While Syria has made modest progress in implementing AML/CFT
regulations that governs the formal financial sector, the continuing
lack of transparency of the state-owned banks and their
vulnerability to political influence reveal the absence of political
will to address AML/CFT in the largest part of the banking sector.
In addition, non-bank financial institutions and the black market
will continue to be vulnerable to money laundering and terrorist
financiers. To build confidence in Syria’s intentions, the Central
Bank should be granted independence and supervisory authority
over the entire sector. Additionally, the Government of Syria
(GOS) should enact the draft AML/CFT law to address many of
the remaining deficiencies. Upon enactment of the new law, Syria
will need to work actively to effectively implement its provisions
through appropriate regulation and other related action. The GOS
should become a party to the UN Convention against Corruption.
The General Directorate of Customs, the Central Bank, and the
judicial system in particular continue to lack the resources and the
political will to effectively implement AML/CFT measures. Although
the GOS has stated its intention to create the technical foundation
through which different government agencies could share
information about financial crimes, this system has not been
created. In addition, it remains doubtful whether the GOS has the
political will to combat terrorist financing by classifying as terrorist
organizations what it currently deems legitimate resistance
groups, or to address the corruption that exists through all levels
of government and business. There is no obligation requiring
financial institutions to report suspicious attempted transactions or
those related to terrorist financing. Many non-bank financial
institutions continue to be unfamiliar with the requirements of the
law.ir
Date: 16 February 2012
Syria has taken significant steps towards improving its AML/CFT
regime, including by improving the legal arrangements for
freezing terrorist assets. However, despite Syria’s high-level
political commitment to work with the FATF and MENAFATF,
further engagement with Syria is needed to clarify whether the
remaining deficiencies have been addressed, including by: (1)
implementing adequate procedures for identifying and freezing
terrorist assets (Special Recommendation III); (2) ensuring that
financial institutions are aware of and comply with their obligations
to file suspicious transaction reports in relation to ML and FT
(Recommendation 13 and Special Recommendation IV); and (3)
ensuring that appropriate laws and procedures are in place to
provide mutual legal assistance (Recommendations 36-38,
Special Recommendation V). The FATF encourages Syria to
demonstrate that its remaining deficiencies have been addressed
to enable the FATF to properly evaluate Syria’s progress.
____________________________________________________
Sanctions:
May 2, 2012 - US President signs an Executive Order (E.O.),
“Prohibiting Certain Transactions with and Suspending Entry into
the United States of Foreign Sanctions Evaders with Respect to
Iran and Syria,” providing the U.S. Treasury Department with a
new authority to tighten further the U.S. sanctions on Iran and
Syria.
Read Executive Order
April 27, 2012 - The Office of Foreign Assets Control has issued
General License 4A, which authorizes the exports or reexports to
Syria of items licensed or otherwise authorized by the Department
of Commerce and of exports and reexports of certain services.
General License 4A replaces and supersedes General License 4,
dated August 18, 2011.
Read License
April 23, 2012 - Executive order blocking the property and
suspending entry into the United States of certain persons with
respect to grave human rights abuses by the governments of Iran
and Syria via information technology
Read Executive Order
March 26. 2012 - Notice for the attention of the persons and
entities to which restrictive measures provided for in Council
Decision 2011/782/CFSP, as implemented by Council
Implementing Decision 2012/172/CFSP, and Council Regulation
(EU) No 36/2012, as implemented by Council Implementing
Regulation (EU) No 266/2012 concerning restrictive measures in
view of the situation in Syria apply
Read More
28 February 2012 - EU Council agreed further restrictive
measures against Syria in its Council Decision 2012/122/CFSP
(“the Decision”) of 27 February 2012
Read Regulation
February 24, 2012 - OFAC has issued General License 15
related to Syria to authorize transactions in connection with
patent, trademark, copyright, or other intellectual property
protection that would otherwise be prohibited by Executive Order
13582.
Read General Licence
January 25, 2012 - EU Council Implement Regulation (EU) No
55/2012 in respect of the restrictive measures directed by the
Council of the European Union in view of the situation in Syria
Read Regulation
January 19, 2012 - The EU has imposed Regulation(EU) No
36/2012 of 18 January 2012 concerning restrictive measures in
view of the situation in Syria and repealing Regulation (EU) No
442/2011
Read Regulation
December 2, 2011 - EU Council implement further sanctions on
Syria - Regulation (EU) No 1244/2011
Read regulation
November 28, 2011 - The Arab League (comprising 22 Arab
member states), of which this country is a member, has approved
imposing sanctions on Syria. These include: -
* Cutting off transactions with the Syrian central bank
* Halting funding by Arab governments for projects in Syria
* A ban on senior Syrian officials travelling to other Arab countries
* A freeze on assets related to President Bashar al-Assad's
government
The declaration also calls on Arab central banks to monitor
transfers to Syria, with the exception of remittances from Syrians
abroad.
Click here for further information
Implementation of COUNCIL REGULATION (EU) No 1150/2011
of 14 November 2011 amending Regulation (EU) No
442/2011 concerning restrictive measures in view of the
situation in Syria
Read Regulation
Council Implementing Regulation (EU) No 1151/2011 of 14
November 2011 implementing Regulation (EU) No 442/2011
concerning restrictive measures in view of the situation in Syria.
Read Regulation
U.S. depository institutions, U.S. registered brokers or dealers in
securities, and U.S. registered money transmitters are authorized
to process funds transfers for the operating expenses or other
official business of third-country diplomatic or consular missions in
Syria, provided that the transfer is not by, to, or through the
Govemment of Syria or any other person whose property and
interests in property are blocked pursuant to previous Executive
Orders
Click here to read General Licence 12
On 18th May, 2011, the US imposed an Executive Order Blocking
Property of Certain Persons with Respect to Human Rights
Abuses in Syria.
This now stands with other types of sanctions that the U.S.
government has imposed against Syria. The most comprehensive
sanction, called the Syria Accountability Act (SAA) of 2004,
prohibits the export of most goods containing more than 10% U.S.-
manufactured component parts to Syria. Another sanction,
resulting from the USA Patriot Act, was levied specifically against
the Commercial Bank of Syria in 2006. The third type of sanction
contains many Executive Orders from the President that
specifically deny certain Syrian citizens and entities access to the
U.S. financial system due to their participation in proliferation of
weapons of mass destruction, association with Al Qaida, the
Taliban or Osama bin Laden; or destabilizing activities in Iraq and
Lebanon.
For further information: -
http://www.treasury.gov/resource-
center/sanctions/Programs/pages/syria.aspx
On 23rd May, 2011, the EU strengthened Restrictive Measures
already in place to include President Bashar A-Assad and certain
members of his regime. For further information, please visit the
following link: -
http://www.consilium.europa.
eu/uedocs/cms_Data/docs/pressdata/EN/foraff/122157.pdf
For further information on EU restrictive measures, please visit
the following link: -
http://ec.europa.
eu/external_relations/cfsp/sanctions/docs/measures_en.pdf
The Arab League (comprising 22 Arab member states), of which
this country is a member, has boycotted Israel in a systematic
effort to isolate Israel economically in support of the Palestinians,
however, the implementation of the boycott has varied over time
among member states..
There are three tiers to the boycott. The primary boycott prohibits
the importation of Israeli-origin goods and services into boycotting
countries. The secondary boycott prohibits individuals, as well as
private and public sector firms and organizations, in member
countries from engaging in business with any entity that does
business in Israel. The Arab League maintains a blacklist of such
firms. The tertiary boycott prohibits any
entity in a member country from doing business with a company or
individual that has business dealings with U.S. or other firms on
the Arab League blacklist.
____________________________________________________
Offshore Jurisdiction Blacklists:
Information unavailable.
____________________________________________________
US State Department Money Laundering Report - 2011
Syria is not an important regional or offshore financial center, due
primarily to its still underdeveloped private banking sector and the
fact that the Syrian pound is not a fully convertible currency.
Despite rapid growth in the banking sector, industry experts
estimate only 20 percent of Syria’s population of nearly 22 million
people actually uses banking services. Consequently, some 60
percent of all business transactions are still conducted in cash.
Estimates of the volume of business conducted in the black
market by Syrian moneychangers range between $15 and $70
million per day. Additionally, there continue to be significant
money laundering and terrorist financing vulnerabilities in Syria’s
banking and non-bank financial sectors due to either a lack of
necessary legislation or poor government enforcement of existing
laws. Syria’s black market moneychangers are not adequately
regulated, and the country’s borders remain porous. Regional
hawala networks, intertwined with smuggling and trade-based
money laundering, raise significant concerns, including
involvement in the financing of terrorism. The most obvious
indigenous money laundering threat involves Syria’s political and
business elite, whose corruption and extra-legal activities continue
unabated.
There are eight public free trade zones (FTZs) in Syria and five
additional free zones are planned in Damascus, Homs, Dayr ez-
Zawr, Idleb, and the port of Tartous. In recent years, both China
and Iran announced plans to build FTZs in Syria, although Iran
later dropped this idea in favor of pursuing a free trade
agreement with Syria. China’s free zone in Adra was officially
inaugurated in July 2008; thirteen businesses have been
established in Adra to-date. The volume of goods entering the
FTZs is estimated to be in the billions of dollars and is growing,
especially with increasing demand for automobiles and automotive
parts, which enter the zones free of customs tariffs before being
imported into Syria. While all industries and financial institutions in
the FTZs must be registered with the General Organization for
Free Zones, part of the Ministry of Economy and Trade, the
Syrian General Directorate of Customs continues to lack strong
procedures to check country of origin certification or the
resources to adequately monitor goods that enter Syria through
the zones. There are also continuing reports of Syrians using the
FTZs to import arms and other goods into Syria in violation of
USG sanctions under the Syrian Accountability Act, and a number
of United Nations Security Council Resolutions.
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: List approach
Legal persons covered: criminally: YES civilly: YES
CRIMINALIZATION OF TERRORIST FINANCING:
Ability to freeze terrorist assets without delay: NO
UN lists of designated terrorists or terrorist entities distributed to
financial institutions: YES
KNOW-YOUR-CUSTOMER RULES:
Covered entities: Banks; money exchanges and remitters; issuers
of payment instruments such as credit cards, payment cards,
travelers checks, and ATM cards; investment funds and their
managers; financial brokerages and financial leasing
corporations; insurance companies; real-estate brokers and
agents; dealers of high-value goods, such as jewelry, precious
stones, gold, and antiquities; lawyers; and accountants
Enhanced due diligence procedures for PEPs: Foreign: NO
Domestic: NO
SUSPICIOUS TRANSACTION REPORTING REQUIREMENTS:\
Covered entities: Banks; money exchanges and remitters; issuers
of payment instruments such as credit cards, payment cards,
travelers checks, and ATM cards; investment funds and their
managers; financial brokerages and financial leasing
corporations; insurance companies; real-estate brokers and
agents; dealers of high-value goods, such as jewelry, precious
stones, gold, and antiquities; lawyers; and accountants
Number of STRs received and time frame: 144 from January to
November 2010
Number of CTRs received and time frame: Not available
MONEY LAUNDERING CRIMINAL
PROSECUTIONS/CONVICTIONS:
Prosecutions: Not available
Convictions: 0
Assets forfeited: criminally: Not available civilly: Not available
RECORDS EXCHANGE MECHANISM:
With U.S.: YES
With other governments/jurisdictions: YES
Syria is a member of the Middle East and North Africa Financial
Action Task Force (MENAFATF), a Financial Action Task Force-
style regional body. Syria’s most recent mutual evaluation can be
found at: http://www.menafatf.
org/images/UploadFiles/MutualEvaluationReportofSyria.pdf
ENFORCEMENT AND IMPLEMENTATION ISSUES AND
COMMENTS:
The United States has designated Syria as a State Sponsor of
Terrorism.
In May 2004, the U.S. Department of Treasury found the
Commercial Bank of Syria (CBS), along with its subsidiary, the
Syrian Lebanese Commercial Bank, to be a financial institution of
“primary money laundering concern,” pursuant to Section 311 of
the USA PATRIOT Act. This finding resulted from information that
CBS had been used by terrorists or persons associated with
terrorist organizations as a conduit for the laundering of proceeds
generated from the illicit sale of Iraqi oil, and because of
continued concerns that CBS was vulnerable to exploitation by
criminal and/or terrorist enterprises. In April 2006, Treasury
promulgated a final rule, based on the 2004 finding and proposed
rule-making, prohibiting U.S. financial institutions from maintaining
or opening correspondent or payable-through accounts with CBS
or its Syrian Lebanese Commercial Bank subsidiary.
Most Syrian judges are not yet familiar with the evidentiary
requirements of the anti-money laundering law. Furthermore, the
slow pace of the Syrian legal system and political sensitivities
delay quick adjudication of these issues. The lack of expertise,
further undermined by a lack of political will, continues to impede
effective implementations of existing AML/CFT regulations.
Although Decree 33 provides the Central Bank with the legal basis
to combat money laundering, most Syrians still do not maintain
bank accounts or use checks, credit cards, or ATM machines.
The Syrian economy remains primarily cash-based, and Syrians
use moneychangers, some of whom also act as hawaladars, for
many financial transactions. As a step to enhancing oversight of
moneychangers, in 2006 a law was passed to cover
moneychangers; however, they remain largely unregulated.
In addition to cash smuggling, there is also a high rate of
commodity smuggling out of Syria. It has been reported that some
smuggling is occurring with the knowledge of, or perhaps even
under the authority of, the Syrian security services. The General
Directorate of Customs lacks the necessary staff and financial
resources to effectively handle the problem of smuggling. While
customs has started to enact some limited reforms, including the
computerization of border outposts to interface with other
government agencies, problems of information-sharing remain.
While Syria has made modest progress in implementing AML/CFT
regulations that governs the formal financial sector, the continuing
lack of transparency of the state-owned banks and their
vulnerability to political influence reveal the absence of political
will to address AML/CFT in the largest part of the banking sector.
In addition, non-bank financial institutions and the black market
will continue to be vulnerable to money laundering and terrorist
financiers. To build confidence in Syria’s intentions, the Central
Bank should be granted independence and supervisory authority
over the entire sector. Additionally, the Government of Syria
(GOS) should enact the draft AML/CFT law to address many of
the remaining deficiencies. Upon enactment of the new law, Syria
will need to work actively to effectively implement its provisions
through appropriate regulation and other related action. The GOS
should become a party to the UN Convention against Corruption.
The General Directorate of Customs, the Central Bank, and the
judicial system in particular continue to lack the resources and the
political will to effectively implement AML/CFT measures. Although
the GOS has stated its intention to create the technical foundation
through which different government agencies could share
information about financial crimes, this system has not been
created. In addition, it remains doubtful whether the GOS has the
political will to combat terrorist financing by classifying as terrorist
organizations what it currently deems legitimate resistance
groups, or to address the corruption that exists through all levels
of government and business. There is no obligation requiring
financial institutions to report suspicious attempted transactions or
those related to terrorist financing. Many non-bank financial
institutions continue to be unfamiliar with the requirements of the
law.ir
| ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
|
|
| |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
*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.
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.
|
| Further Tables |
| SYRIA |
| KnowYourCountry |
|
|
| Last Updated: 2 May 2012 |