Dear Colleagues,

We are glad you are looking forward to signing the MOU with us.

We have completed the review of the counterproposal you made, many of the changes proposed by IMPA have been accepted; however, we have a few questions that we would appreciate you could clarify, you can find them in the comments in the document attached.

But the principal change that we are more concerned about is the following insertion: "... without the intent to create a legally binding document but with the purpose of fostering information exchange to the fullest extent possible ..."

We are worried we are not legally able to subscribe an MOU which states it is not legally binding for Guatemala's FIU is mandated by law to subscribe Memorandums of Understanding with counterparts to exchange information, besides it also abides to the Principles for Information Exchange between Financial Intelligence Units, which are binding. For that reason we would like to keep said text as originally proposed: "To that end, having regard to the relevant documents of the Egmont Group ..."

Please let us know your comments of our new proposal. We are interested indeed in building a strong bond between our Units that allows us to cooperate and combat ML/TF.

We look forward to hearing from you at your earliest convenience.

Best regards,

IVE-GUATEMALA

 

 

El 10/04/2019 a las 06:50, Lynn Lerer escribió:

Dear Colleagues,

Thank you once again for reaching out to us regarding the signature of a MoU between our two countries. We are greatly looking forward to the cooperation and exchange of information of our FIUs.

We have reviewed the proposed draft which you sent us and have added our input, which we hope is to your content.

Once you have reviewed and approved the proposed draft we will be happy to proceed with the signature of the MoU.

Best regards,

Lynn

On 10/03/2019 18:00, IMPA-ISRAEL wrote:

 

-------- Forwarded Message --------

Subject:	MOU Negotiation IL-GT
Date:	Thu, 07 Mar 2019 08:26:55 -0600
From:	IVE-Guatemala <ive-guatemala@egmont.org>
To:	IMPA - Israel <impa@egmont.org>

Dear Colleagues,

Please receive our kindest greetings from Guatemala’s Financial Intelligence Unit (IVE).

We take great pleasure in addressing the Israel Money Laundering and Terror Financing Prohibition Authority (IMPA) to propose signing a Memorandum of Understanding to enhance cooperation and strengthen exchange of information between our Units to prevent, detect, and counter money laundering and terrorism financing.

Our AML/CTF legislation requires us to sign an MOU; therefore, we kindly invite you to review at your earliest convenience our proposed draft, which is based in the Egmont Group model MoU; we will absolutely welcome any comments or suggestions you may have.

Please do not hesitate to contact us, we will gladly answer any inquiries regarding our legal framework, scope of our task functions, or any inquiry you may have.

We are looking forward to hearing from you.

Best regards,

 

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