| Subject: | Re: Postponement / suspension of transactions |
|---|---|
| Date: | Tue, 14 Jan 2020 16:12:05 +0200 |
| From: | ONPCSB <onpcsb@egmont.org> |
| To: | IMPA-ISRAEL <impa@egmont.org> |
Dear Colleagues,
Israel is considering amending its legislation to provide IMPA with the authority to postpone/suspend transactions on the basis of a request from Israeli LEAs and foreign FIUs.
We would greatly appreciate your input with regard to the legislation and practical procedures in your country concerning the following issues:
1. What is the evidentiary threshold required (of the FIU) to suspend a transaction?
2. What type of evidence is required by the FIU in order to substantiate a suspension order (e.g. suspicious transactions, additional intelligence, information from other sources)?
3. Is there a time limitation to the postponement/suspension order? If so, what is the limitation?
4. In practice what is the average length of time your FIU actually suspends transactions?
5. How many transactions does your FIU suspend per year? How many of these cases triggered an investigation in your country?
6. Do any other LEAs have a similar suspension/postponement/freezing authority of transactions or funds or other assets?
7. If so:
a. which LEAs?
b. Do the LEAs and FIU employ their authority simultaneously? (i.e. in what circumstances is each suspension/postponement/freezing authority employed?)
c. What is the difference between the suspension authority of the FIU and the seizure authority of the police/LEAs?
8. Is the FIU/other authority required to inform the suspect regarding the suspension. If so, at which stage?
Thank you in advance for your assistance on this matter,
Best regards,
IMPA