DOCSLIB.ORG

MER-Greece-2019.Pdf

Total Page：16

File Type：pdf, Size：1020Kb

Download full-text PDF Read full-text
MER-Greece-2019.Pdf Anti-money laundering and counter-terrorist financing measures financing counter-terrorist and laundering Anti-money Anti-money laundering and counter-terrorist financing measures Greece Mutual Evaluation Report Greece September 2019 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes policies to protect the global financial system against money laundering, terrorist financing and the financing of proliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-money laundering (AML) and counter-terrorist financing (CTF) standard. For more information about the FATF, please visit the website: www.fatf-gafi.org. This document and/or any map included herein are without prejudice to the status of or sovereignty over any territory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. This assessment was adopted by the FATF at its June 2019 Plenary meeting. Citing reference: FATF (2019), Anti-money laundering and counter-terrorist financing measures – Greece, Fourth Round Mutual Evaluation Report, FATF, Paris http://www.fatf-gafi.org/publications/mutualevaluations/documents/mer-greece-2019.html © 2019 FATF-. All rights reserved. No reproduction or translation of this publication may be made without prior written permission. Applications for such permission, for all or part of this publication, should be made to the FATF Secretariat, 2 rue André Pascal 75775 Paris Cedex 16, France (fax: +33 1 44 30 61 37 or e-mail: [email protected]). Photo Credit - Cover: © Stratos Kalafatis, Archipelago, Agra Publications, 2017 Table of Contents Key Findings .................................................................................................................................................................... 3 Risks and General Situation ...................................................................................................................................... 5 Overall Level of Compliance and Effectiveness ................................................................................................ 5 Priority Actions ............................................................................................................................................................ 11 MUTUAL EVALUATION REPORT ............................................................................................................... 13 Preface ............................................................................................................................................................................. 13 Chapter 1. ML/TF RISKS AND CONTEXT ................................................................................................ 15 ML/TF Risks and Scoping of Higher Risk Issues ............................................................................................ 17 Materiality ...................................................................................................................................................................... 21 Structural Elements .................................................................................................................................................... 22 Background and Other Contextual Factors ...................................................................................................... 22 Chapter 2. NATIONAL AML/CFT POLICIES AND CO-ORDINATION ............................................... 33 Key Findings and Recommended Actions ......................................................................................................... 33 Immediate Outcome 1 (Risk, Policy and Co-ordination) ............................................................................ 34 Chapter 3. LEGAL SYSTEM AND OPERATIONAL ISSUES ................................................................... 43 Key Findings and Recommended Actions ......................................................................................................... 43 Immediate Outcome 6 (Financial Intelligence ML/TF) ............................................................................... 47 Immediate Outcome 7 (ML investigation and prosecution) ..................................................................... 58 Immediate Outcome 8 (Confiscation) ................................................................................................................. 69 Chapter 4. TERRORIST FINANCING AND FINANCING OF PROLIFERATION ............................... 75 Key Findings and Recommended Actions ......................................................................................................... 75 Immediate Outcome 9 (TF investigation and prosecution) ...................................................................... 77 Immediate Outcome 10 (TF preventive measures and financial sanctions) ...................................... 84 Immediate Outcome 11 (PF financial sanctions) ........................................................................................... 88 Chapter 5. PREVENTIVE MEASURES ....................................................................................................... 93 Key Findings and Recommended Actions ......................................................................................................... 93 Immediate Outcome 4 (Preventive Measures) ............................................................................................... 95 Chapter 6. SUPERVISION ........................................................................................................................... 109 Key Finding and Recommended Actions ........................................................................................................ 109 Immediate Outcome 3 (Supervision) ............................................................................................................... 111 Chapter 7. LEGAL PERSONS AND ARRANGEMENTS ......................................................................... 125 Key Finding and Recommended Actions ........................................................................................................ 125 Immediate Outcome 5 (Legal Persons and Arrangements) ................................................................... 126 Chapter 8. INTERNATIONAL CO-OPERATION .................................................................................... 131 Key Finding and Recommended Actions ........................................................................................................ 131 Immediate Outcome 2 (International Co-operation) ................................................................................ 133 2 TECHNICAL COMPLIANCE ANNEX .......................................................................................................... 153 Recommendation 1 – Assessing risks and applying a risk-based approach.................................... 153 Recommendation 2 - National Co-operation and Co-ordination .......................................................... 155 Recommendation 3 - Money laundering offence ........................................................................................ 156 Recommendation 4 - Confiscation and provisional measures .............................................................. 157 Recommendation 5 - Terrorist financing offence ....................................................................................... 159 Recommendation 6 - Targeted financial sanctions related to terrorism and terrorist financing160 Recommendation 7 – Targeted financial sanctions related to proliferation ................................... 166 Recommendation 8 – Non-profit organisations .......................................................................................... 168 Recommendation 9 – Financial institution secrecy laws ........................................................................ 173 Recommendation 10 – Customer due diligence .......................................................................................... 174 Recommendation 11 – Record-keeping .......................................................................................................... 177 Recommendation 12 – Politically exposed persons .................................................................................. 178 Recommendation 13 – Correspondent banking .......................................................................................... 179 Recommendation 14 – Money or value transfer services ....................................................................... 180 Recommendation 15 – New technologies ...................................................................................................... 181 Recommendation 16 – Wire transfers ............................................................................................................ 182 Recommendation 17 – Reliance on third parties ........................................................................................ 184 Recommendation 18 – Internal controls and foreign branches and subsidiaries ........................ 186 Recommendation 19 – Higher-risk countries .............................................................................................. 187 Recommendation 20 – Reporting of suspicious transaction ................................................................. 188 Recommendation 21 – Tipping-off
Load more

Recommended publications
  • Internet Banking in Greece -Trends and Practices- a Research and Analysis in Availability and Use of Internet Banking
    THE UNIVERSITY OF GREENWICH BUSINESS SCHOOL Internet Banking in Greece -Trends and Practices- A research and analysis in availability and use of internet banking Dissertation submitted in accordance with the requirements of the University of Greenwich for the degree of MSc in Finance and Financial Information Systems By Nikolaos Satsios (I.D.Number: 000491875) Kavala, 2009 INDEX ACKNOWLEDGEMENTS ..................................................................................................... 3 ABSTRACT ............................................................................................................................. 4 1. INTRODUCTION ................................................................................................................ 5 2. LITERATURE REVIEW .................................................................................................... 7 2.1 Basic characteristics of the Greek Banking system ..................................................... 11 2.2 Productivity of the Banking system ............................................................................. 13 2.2.1 Advantages and disadvantages of e - banking from the side of customers ........... 13 2.2.2 Advantages and disadvantages of e - banking from the side of banks .................. 15 2.4 Starting Line and Development of Electronic Banking ............................................... 18 2.5 The influence of e-banking in the behaviour of consumers ......................................... 20 3 SECURITY IN E-BANKING ............................................................................................
    [Show full text]
  • National Bank of Greece (NBG) Memo Name: James Zhang Phone #: (757) 788-9962 College/School: CLAS Year: Class of 2017
    National Bank of Greece (NBG) Memo Name: James Zhang Phone #: (757) 788-9962 College/School: CLAS Year: Class of 2017 Company Description [NYSE; NGB] is a Greek bank and financial services company that primarily operates in commercial banking, but also has business in retail banking, investment banking, asset management, and insurance. The National Bank of Greece SA previously wrote off huge losses on its balance sheet during the Eurozone debt crisis, it has been on a steady path to recovery since the second half of 2013, and has been expanding its business in various sectors throughout Europe. Specifically, the rise in Greek lending and home loans, diversification by way of improved operations in Turkey and emerging markets, and the general recovery of the Greek economy will propel NGB to huge growth in the long term. Most notably, recent actions by Mario Draghi and the European Central Bank will create a healthy, stable environment for the National Bank of Greece to achieve its upside potential over time. Thesis / Key Points Rise in lending and specific developments in the banking sector in Greece will play to NBG’s advantage As Greece’s largest lender, NBG has acted swiftly in the past year to boost its position financially by increasing loans and retailing banking, as well as increasing capitalization from outside investors and generating domestic confidence. o Its nonperforming loans (NLP) have receded drastically and will contribute to its profitability when compared with its 3 closest rivals, Piraeus Bank, Alpha Bank, and EuroBank, who have all booked operating losses in this field. In addition, NGB now controls a quarter of commercial banking in Greece and 25% of total consumer deposits, and has also proceeded to raise around €2.5 billion in capital to reduce the Greece government’s holding stake in the bank.
    [Show full text]
  • Understanding the Value of Arts & Culture | the AHRC Cultural Value
    Understanding the value of arts & culture The AHRC Cultural Value Project Geoffrey Crossick & Patrycja Kaszynska 2 Understanding the value of arts & culture The AHRC Cultural Value Project Geoffrey Crossick & Patrycja Kaszynska THE AHRC CULTURAL VALUE PROJECT CONTENTS Foreword 3 4. The engaged citizen: civic agency 58 & civic engagement Executive summary 6 Preconditions for political engagement 59 Civic space and civic engagement: three case studies 61 Part 1 Introduction Creative challenge: cultural industries, digging 63 and climate change 1. Rethinking the terms of the cultural 12 Culture, conflict and post-conflict: 66 value debate a double-edged sword? The Cultural Value Project 12 Culture and art: a brief intellectual history 14 5. Communities, Regeneration and Space 71 Cultural policy and the many lives of cultural value 16 Place, identity and public art 71 Beyond dichotomies: the view from 19 Urban regeneration 74 Cultural Value Project awards Creative places, creative quarters 77 Prioritising experience and methodological diversity 21 Community arts 81 Coda: arts, culture and rural communities 83 2. Cross-cutting themes 25 Modes of cultural engagement 25 6. Economy: impact, innovation and ecology 86 Arts and culture in an unequal society 29 The economic benefits of what? 87 Digital transformations 34 Ways of counting 89 Wellbeing and capabilities 37 Agglomeration and attractiveness 91 The innovation economy 92 Part 2 Components of Cultural Value Ecologies of culture 95 3. The reflective individual 42 7. Health, ageing and wellbeing 100 Cultural engagement and the self 43 Therapeutic, clinical and environmental 101 Case study: arts, culture and the criminal 47 interventions justice system Community-based arts and health 104 Cultural engagement and the other 49 Longer-term health benefits and subjective 106 Case study: professional and informal carers 51 wellbeing Culture and international influence 54 Ageing and dementia 108 Two cultures? 110 8.
    [Show full text]
  • Panel 3 CIVIL SOCIETY-ORGANISATIONS
    Greek Ethical Identities in Continuity and Change: A Social Networks Approach of Applied Philotimo in Economo-scape of Local Communities; the Case of Cooperative Banking Theodoros A. Katerinakis, MSc, PhD Candidate Tel: +215 895 6143, e-mail: [email protected] Department of Culture & Communication, Drexel University, 3141 Chestnut St., Philadelphia, PA 19104, USA Μail Address: 106A North 21st St., Philadelphia, PA 19103, USA Abstract: The core value of Greek philotimo derives from the root concept of kalokagathia and is manifested in the institutional and transactional ethos of Cooperative Banks in Greece. A major case study of Cooperative Bank of Chania (CBC) is presented to introducing the analytical approach of social network analysis, via UCINET, to represent membership ties and managerial ties in the second largest Greek cooperative bank. The concept of ethics in doing business is extended in a deliberate tendency to build transactional networks that enforce pre-existing social networks and stay tuned with sustainable local economies, a notion consistent with locality in multicultural Europe. Cooperative banking operates in intersection of emotional capitalism and social enterprise, as a cultural process through which new interactional- emotional scripts of economic relationships are illustrated by the cultural frames of cooperation or team work. The case of CBC of Chania shows how non-commercial ties of buyers- sellers matter in “major purchases” and insulate from crisis. Most such transactions take place among kin, friends, or acquaintances that substitute impersonal markets, especially when decisions involve high uncertainty; so common values like philotimo promote connectedness and builds trust that prevails in dealing with risk in order to make financial decisions, sustain and support them.
    [Show full text]
  • Albanian Families' History and Heritage Making at the Crossroads of New
    Voicing the stories of the excluded: Albanian families’ history and heritage making at the crossroads of new and old homes Eleni Vomvyla UCL Institute of Archaeology Thesis submitted for the award of Doctor in Philosophy in Cultural Heritage 2013 Declaration of originality I, Eleni Vomvyla confirm that the work presented in this thesis is my own. Where information has been derived from other sources, I confirm that this has been indicated in the thesis. Signature 2 To the five Albanian families for opening their homes and sharing their stories with me. 3 Abstract My research explores the dialectical relationship between identity and the conceptualisation/creation of history and heritage in migration by studying a socially excluded group in Greece, that of Albanian families. Even though the Albanian community has more than twenty years of presence in the country, its stories, often invested with otherness, remain hidden in the Greek ‘mono-cultural’ landscape. In opposition to these stigmatising discourses, my study draws on movements democratising the past and calling for engagements from below by endorsing the socially constructed nature of identity and the denationalisation of memory. A nine-month fieldwork with five Albanian families took place in their domestic and neighbourhood settings in the areas of Athens and Piraeus. Based on critical ethnography, data collection was derived from participant observation, conversational interviews and participatory techniques. From an individual and family group point of view the notion of habitus led to diverse conceptions of ethnic identity, taking transnational dimensions in families’ literal and metaphorical back- and-forth movements between Greece and Albania.
    [Show full text]
  • List of Certain Foreign Institutions Classified As Official for Purposes of Reporting on the Treasury International Capital (TIC) Forms
    NOT FOR PUBLICATION DEPARTMENT OF THE TREASURY JANUARY 2001 Revised Aug. 2002, May 2004, May 2005, May/July 2006, June 2007 List of Certain Foreign Institutions classified as Official for Purposes of Reporting on the Treasury International Capital (TIC) Forms The attached list of foreign institutions, which conform to the definition of foreign official institutions on the Treasury International Capital (TIC) Forms, supersedes all previous lists. The definition of foreign official institutions is: "FOREIGN OFFICIAL INSTITUTIONS (FOI) include the following: 1. Treasuries, including ministries of finance, or corresponding departments of national governments; central banks, including all departments thereof; stabilization funds, including official exchange control offices or other government exchange authorities; and diplomatic and consular establishments and other departments and agencies of national governments. 2. International and regional organizations. 3. Banks, corporations, or other agencies (including development banks and other institutions that are majority-owned by central governments) that are fiscal agents of national governments and perform activities similar to those of a treasury, central bank, stabilization fund, or exchange control authority." Although the attached list includes the major foreign official institutions which have come to the attention of the Federal Reserve Banks and the Department of the Treasury, it does not purport to be exhaustive. Whenever a question arises whether or not an institution should, in accordance with the instructions on the TIC forms, be classified as official, the Federal Reserve Bank with which you file reports should be consulted. It should be noted that the list does not in every case include all alternative names applying to the same institution.
    [Show full text]
  • Greece in a Monetary Union: Lessons from 100 Years of Exchange-Rate Experience
    Greece in a Monetary Union: Lessons from 100 Years of Exchange-Rate Experience Paper prepared for Bank of Greece Research Seminar (Wednesday 4th January 2017, 11:00 a.m., Athens, Greece) & American Economic Association Annual Meeting Chicago/IL 6th – 8th January, 2017 (Saturday 7th January, 10:15 a.m., Hyatt Regency Chicago, Horner Room) Dr. Matthias Morys Department of Economics University of York (UK) [email protected] Abstract We add a historical and regional dimension to the debate on the Greek debt crisis. Analysing Greece, Romania, Serbia/Yugoslavia and Bulgaria from political independence to WW II, we find surprising parallels to the present: repeated cycles of entry to and exit from monetary unions, government debt build-up and default, and financial supervision by West European countries. Gold standard membership was more short-lived than in any other part of Europe due to fiscal dominance. Granger causality tests and money growth accounting show that the prevailing pattern of fiscal dominance was only broken under international financial control, when strict conditionality scaled back the treasury’s influence; only then were central banks able to conduct a rule-bound monetary policy and stabilize their exchange-rates. The long- run record of Greece suggests that the perennial economic and political objective of monetary union membership can only be maintained and secured if both monetary and fiscal policy remains firmly anchored in a European institutional framework. Keywords: fiscal dominance, gold standard, financial
    [Show full text]
  • Energy Performance Certification of Buildings a Policy Tool to Improve Energy Efficiency
    Energy Performance Certification of Buildings A policy tool to improve energy efficiency Policy Pathway Energy Performance Certification of Buildings A policy tool to improve energy efficiency The IEA Policy Pathway series Policy Pathway publications provide details on how to implement specific recommendations drawn from the IEA’s 25 Energy Efficiency Policy Recommendations. Based on direct experience, published research, expert workshops and best-practice country case studies, the series aims to provide guidance to all countries on the essential steps and milestones in implementing specific energy efficiency policies. POLICY The Policy Pathways series is designed for policy makers at all levels of government E PATHWAY AT and other relevant stakeholders who seek U practical ways to develop, support, monitor L or modify energy efficiency policies in their A P V L home country and abroad. The Pathways A can also provide insight into the types of E N policies best adapted to the specific policy context(s) of different countries, so that each country derives the maximum benefit from M energy efficiency improvements. O N T I T N O E R M E L IMP IEA POLICY PATHWAY ENERGY PERFORMANCE CERTIFICATION OF BUILDINGS 1 INTERNATIONAL ENERGY AGENCY The International Energy Agency (IEA), an autonomous agency, was established in November 1974. Its mandate is two-fold: to promote energy security amongst its member countries through collective response to physical disruptions in oil supply and to advise member countries on sound energy policy. The IEA carries out a comprehensive programme of energy co-operation among 28 advanced economies, each of which is obliged to hold oil stocks equivalent to 90 days of its net imports.
    [Show full text]
  • The Rise and Fall of the 5/42 Regiment of Evzones: a Study on National Resistance and Civil War in Greece 1941-1944
    The Rise and Fall of the 5/42 Regiment of Evzones: A Study on National Resistance and Civil War in Greece 1941-1944 ARGYRIOS MAMARELIS Thesis submitted in fulfillment of the requirements for the degree of Doctor in Philosophy The European Institute London School of Economics and Political Science 2003 i UMI Number: U613346 All rights reserved INFORMATION TO ALL USERS The quality of this reproduction is dependent upon the quality of the copy submitted. In the unlikely event that the author did not send a complete manuscript and there are missing pages, these will be noted. Also, if material had to be removed, a note will indicate the deletion. Dissertation Publishing UMI U613346 Published by ProQuest LLC 2014. Copyright in the Dissertation held by the Author. Microform Edition © ProQuest LLC. All rights reserved. This work is protected against unauthorized copying under Title 17, United States Code. ProQuest LLC 789 East Eisenhower Parkway P.O. Box 1346 Ann Arbor, Ml 48106-1346 9995 / 0/ -hoZ2 d X Abstract This thesis addresses a neglected dimension of Greece under German and Italian occupation and on the eve of civil war. Its contribution to the historiography of the period stems from the fact that it constitutes the first academic study of the third largest resistance organisation in Greece, the 5/42 regiment of evzones. The study of this national resistance organisation can thus extend our knowledge of the Greek resistance effort, the political relations between the main resistance groups, the conditions that led to the civil war and the domestic relevance of British policies.
    [Show full text]
  • Comparing Classifications Feature Films and Video Games
    Comparing Classifications feature films and video games 2012 & 2013 October 2014 Office of Film and Literature Classification Comparing Classifications 2012 & 2013 2 Office of Film and Literature Classification Comparing Classifications 2012 & 2013 Comparing Classifications: feature films and video games 2012 & 2013 Office of Film and Literature Classification Te Tari Whakarōpū Tukuata, Tuhituhinga Level 1, 88 The Terrace PO Box 1999 Wellington 6140 Phone 04 471 6770 Fax 04 471 6781 Email [email protected] Web www.classificationoffice.govt.nz ISBN: PDF 978-0-477-10417-3 This work is licensed under the Creative Commons Attribution 3.0 New Zealand licence. In general, you are free to copy, distribute and adapt the work, as long as you attribute the work to the Office of Film and Literature Classification and abide by the other license terms. To view a copy of this license, please visit http://creativecommons.org/licenses/by/3.0/. Please note that the Office of Film and Literature Classification may not be used in any way that infringes any provision of the Flags, Emblems, and Names Protection Act 1981. Attribution to the Office of Film and Literature Classification should be in written form and not by reproduction of any such emblem or logo. Acknowledgements The Classification Office is grateful to Nokuthaba Sibanda and Lara Wieser from the School of Mathematics, Statistics and Operations Research at Victoria University of Wellington who worked with us in 2009 to develop the scoring methodology and the analytical approaches used in this report. We are also grateful to Mike Camden of Statistics NZ who helped us in 2010 to present the data graphically.
    [Show full text]
  • A HISTORY of the PELASGIAN THEORY. FEW Peoples Of
    A HISTORY OF THE PELASGIAN THEORY. FEW peoples of the ancient world have given rise to so much controversy as the Pelasgians; and of few, after some centuries of discussion, is so little clearly established. Like the Phoenicians, the Celts, and of recent years the Teutons, they have been a peg upon which to hang all sorts of speculation ; and whenever an inconvenient circumstance has deranged the symmetry of a theory, it has been safe to ' call it Pelasgian and pass on.' One main reason for this ill-repute, into which the Pelasgian name has fallen, has been the very uncritical fashion in which the ancient statements about the Pelasgians have commonly been mishandled. It has been the custom to treat passages from Homer, from Herodotus, from Ephorus, and from Pausanias, as if they were so many interchangeable bricks to build up the speculative edifice; as if it needed no proof that genealogies found sum- marized in Pausanias or Apollodorus ' were taken by them from poems of the same class with the Theogony, or from ancient treatises, or from prevalent opinions ;' as if, further, ' if we find them mentioning the Pelasgian nation, they do at all events belong to an age when that name and people had nothing of the mystery which they bore to the eyes of the later Greeks, for instance of Strabo;' and as though (in the same passage) a statement of Stephanus of Byzantium about Pelasgians in Italy ' were evidence to the same effect, perfectly unexceptionable and as strictly historical as the case will admit of 1 No one doubts, of course, either that popular tradition may transmit, or that late writers may transcribe, statements which come from very early, and even from contemporary sources.
    [Show full text]
  • By Konstantinou, Evangelos Precipitated Primarily by the Study
    by Konstantinou, Evangelos Precipitated primarily by the study of ancient Greece, a growing enthusiasm for Greece emerged in Europe from the 18th century. This enthusiasm manifested itself in literature and art in the movements referred to as classicism and neoclassicism. The founda- tions of contemporary culture were identified in the culture of Greek antiquity and there was an attempt to learn more about and even revive the latter. These efforts manifested themselves in the themes, motifs and forms employed in literature and art. How- ever, European philhellenism also had an effect in the political sphere. Numerous societies were founded to support the cause of Greek independence during the Greek War of Independence, and volunteers went to Greece to join the fight against the Ottoman Empire. Conversely, the emergence of the Enlightenment in Greece was due at least in part to the Greek students who studied at European universities and brought Enlightenment ideas with them back to Greece. TABLE OF CONTENTS 1. Literary and Popular Philhellenism in Europe 2. European Travellers to Greece and Their Travel Accounts 3. The Greek Enlightenment 4. Reasons for Supporting Greece 5. Philhellenic Germany 6. Lord Byron 7. European Philhellenism 8. Societies for the Support of the Greeks 9. Bavarian "State Philhellenism" 10. Jakob Philip Fallmerayer and Anti-Philhellenism 11. Appendix 1. Sources 2. Bibliography 3. Notes Indices Citation The neo-humanism of the 18th and 19th centuries contributed considerably to the emergence of a philhellenic1 climate in Europe. This new movement was founded by Johann Joachim Winckelmann (1717–1768) (ᇄ Media Link #ab), who identified aesthetic ideals and ethical norms in Greek art, and whose work Geschichte der Kunst des Altertums (1764) (ᇄ Media Link #ac) (History of the Art of Antiquity) made ancient Greece the point of departure for an aestheticizing art history and cultural history.
    [Show full text]