Date : 11/7/2019 6:13:40 PM
To : "JoanneO@justice.gov.il"
Subject : EUROPE II Framework for Conducting Strategic Analyses Regarding Laundering the Proceeds of Corruption
Attachment : Framework for conducting of strategic analises on ML of corruption.docx;





-------- Forwarded Message --------
Subject: EUROPE II Framework for Conducting Strategic Analyses Regarding Laundering the Proceeds of Corruption
Date: Thu, 07 Nov 2019 12:03:08 -0500
From: Nedko Krumov <nedko.krumov@egmont.org>
To:


Letter on behalf of the Regional Representative - Mr. Daniel Thelesklaf


Dear EUROPE II members,

 

We hope this letter finds you well!

We would like to thank you very much for your great cooperation and input regarding the development of the Framework for Conducting Strategic Analyses Regarding Laundering the Proceeds of Corruption.

As you remember this project was taken on board during the Regional meeting in Buenos Aires (in March 2018) and it was included in the EUROPE II Regional Plan (2018 - 2021) as one of the projects with key priority. In this sense, FIU Serbia, FIU Ukraine, FIU Holy See, and FIU Guernsey, FIU of the Principality of Liechtenstein supported by the Regional Representatives, formed a working group with the main task of producing the framework. In order to do that, the FIUs within the working group conducted their own high level analyses taking into consideration internal data from their jurisdictions, such as STRs/SARs, law enforcement information, data from foreign counterparts (where applicable), amongst other data, as well as external information (for example, information from open source intelligence and media reports). They also examined the nature of the corruption; the types of assets held; the existence of a foreign element; the involvement of PEPs, or persons / entities related to PEPs; the involvement of third party enablers; the usefulness of international cooperation and the efficiency of the information exchange channels, etc.

The high-level analyses looked at actual cases of laundering the proceeds of corruption, with a particular focus on grand corruption, and identify relevant trends. Taking into consideration the regional diversity, these analyses were used to develop a framework for the analysis of the laundering of the proceeds of corruption. The framework can be used to prepare analyses for the Europe II Region and in addition, the framework may also be shared more widely.

The first meeting of the working group took place in early July 2018. The working group continued its further work based on the division of responsibilities. The working group reported the main steps of its activities during the Regional meetings in Sydney (September 2018) and Strasbourg (December 2018). The first draft of the Framework was presented for discussion during the Regional meeting in The Hague (July 2019). Afterwards, based on the decision taken in The Hague, the draft was disseminated among the EUROPE II members for comments with a deadline - August 16th, 2019. All received comments were implemented and the final draft is now ready to be discussed and approved during the Regional meeting in Strasbourg - December 2019.

Please see attached the final draft of the EUROPE II Framework for Conducting Strategic Analyses Regarding Laundering the Proceeds of Corruption.

Thank you very much for your constant support and assistance.

 

Kind regards,

EGS