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International Monetary Fund
This report was prepared by the Legal Department of the International Monetary Fund (IMF). It provides a summary of the Antimony Laundering and Combating the Financing of Terrorism (AML/CFT) measures in place in St. Vincent and the Grenadines (SVG) and of the level of compliance with the FATF 40+9 Recommendations, and contains recommendations on how the AML/CFT system could be strengthened. The assessment is based on the information available at the time of the mission. The preventive measures regime covers most of the financial and designated nonfinancial businesses and professions (DNFBP) sectors.
International Monetary Fund. Legal Dept.

of bearer share companies and the settlors and ultimate beneficiaries of trusts is weak. 21. Internal AML/CFT controls are stronger in the banking sector but weaker in others . In particular, shortcomings were identified in CDD procedures, internal audit, and employee due diligence requirements. Implementation of AML/CFT requirements is generally weak in the nonbanking sectors partly due to weak oversight. 22. All covered financial institutions are subject to recordkeeping requirements that are broadly in line with the FATF standard . Records must be retained

International Monetary Fund. Legal Dept.
This report assesses the Observance of Standards and Codes on the Financial Action Task Force (FATF) Recommendations for Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) in Panama. Panama is vulnerable to money laundering from a number of sources, including drug trafficking and other predicate crimes committed abroad—such as fraud and financial and tax crimes. Panama has criminalized money laundering and terrorism financing, but its AML/CFT framework is not fully in line with the FATF recommendations. Some requirements form combating the financing of terrorism are included in subsidiary instruments, but these appear to go beyond the AML Law and, therefore, are inconsistent with the legal principles established under the Constitution. There are inadequate statistics on money laundering investigations, prosecutions, and convictions to properly assess the effectiveness of implementation of the legislation.
International Monetary Fund

shareholder of a Mexican entity can be a foreign bearer share company incorporated in a jurisdiction that allows the issuance of such shares. Mexico does not have specific measures in place to help prevent Mexican subsidiaries of such bearer share companies from being used for illicit ML. 35. Only designated licensed financial institutions may administer “ fideicomisos ” in Mexico. Financial institutions are covered by the preventive measures applicable to them and are hence required to obtain, verify, and retain details of the “ fideicomisos ”, including beneficial

International Monetary Fund
This report examines Mexico’s observance of Standards and Codes on the Financial Action Task Force on Money Laundering's recommendations for antimoney laundering and combating the financing of terrorism. The Mexican government has instituted unprecedented measures to support law enforcement activities against organized crime and drug trafficking. The authorities have approved an Integral Strategy against Organized Crime, and various key national stakeholders have executed an interagency agreement entitled the National Agreement for Security, Justice, and Legality.
International Monetary Fund

not explicitly cover mutual fund and life insurance sector intermediaries and should, for the avoidance of doubt, list all FIs specifically covered by SVG financial legislation. More strict enforcement of compliance by supervisors is required to ensure more effective implementation of the existing CDD requirements. The regulations should include enhanced requirements for ML/FT risk management and controls especially with respect to higher risk customers e.g. bearer share companies, politically-exposed persons (PEPs), non-residents, and correspondent banking

International Monetary Fund

. Escalation procedures above the supervisor level are needed for high risk accounts. Know-your-customer requirements or guidelines should be improved for low-risk customers and beneficial owners, and in particular address bearer share companies. Politically exposed persons (PEPs) should be defined to include all relevant politicians (according to Financial Action Task Force (FATF) definitions). 19. Supervisory approach The CNB takes a number of approaches to understand the risks facing individual banks and the banking sector. 20. Supervisory techniques Full

International Monetary Fund. Legal Dept.
This report evaluates the level of implementation of Financial Action Task Force (FATF) Recommendations for Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) in Panama. The findings reveal that Panama is vulnerable to money laundering from a number of sources, including drug trafficking and other predicate crimes committed abroad, such as fraud and financial and tax crimes. The AML Law covers most of the core financial sectors but does not fully apply to the insurance sector and does not extend to a number of other financial activities as required under the FATF standard. Competent authorities, including law enforcement and the Financial Intelligence Unit, do not have timely access to information on legal persons and arrangements as required under the FATF standard.
International Monetary Fund. Legal Dept.

. In particular, identification and verification of beneficial owners or controllers of bearer share companies and the settlors and ultimate beneficiaries of trusts is weak. 21. Internal AML/CFT controls are stronger in the banking sector but weaker in others . In particular, shortcomings were identified in CDD procedures, internal audit, and employee due diligence requirements. Implementation of AML/CFT requirements is generally weak in the nonbanking sectors partly due to weak oversight. 22. All covered financial institutions are subject to recordkeeping

THOMAS C. BAXTER

, certain corporate structures that facilitate nominee ownership, such as bearer share companies, similarly frustrate consolidated supervision. Secrecy Laws Adequate consolidated supervision of a multinational bank such as BCCI requires a significant amount of cross-border information sharing among supervisors. Bank secrecy laws, however, substantially impede the dissemination of information. For example, they make it difficult for a home supervisor to secure from jurisdictions where subsidiaries operate the information needed to understand the condition of the