APG assessment of the anti-money laundering and counter-terrorist financing (AML/CFT) measures in Vanuatu. Ratings of the levels of technical compliance and effectiveness.
1. Anti-money laundering and counter-terrorist financing measures in Vanuatu โ Mutual Evaluation Report โ September 2015 1
Anti-money laundering and counter-
terrorist financing (AML/CTF)
measures in Vanuatu
Mutual Evaluation
Ratings
September 2015
www.fatf-gafi.org/publications/mutualevaluations/documents/mer-vanuatu-2015.html
2. Anti-money laundering and counter-terrorist financing measures in Vanuatu โ Mutual Evaluation Report โ September 2015
Ratings โ Effectiveness (1/3)
2
Immediate outcome of an effective system to combat money
laundering (ML) and terrorist financing (TF)
Extent to which
Vanuatu has
achieved this
objective
1 ML and TF risks are understood and, where appropriate,
actions co-ordinated domestically to combat ML and TF
Low
2 International co-operation delivers appropriate information,
financial intelligence, and evidence, and facilitates action
against criminals and their assets
Low
3 Supervisors appropriately supervise, monitor and regulate
financial institutions and designated non-financial
businesses and professions (DNFBPs) for compliance with
AML/CFT requirements commensurate with their risks.
Low
4 Financial institutions and DNFBPs adequately apply
AML/CFT preventive measures commensurate with their
risks, and report suspicious transactions.
Low
3. Anti-money laundering and counter-terrorist financing measures in Vanuatu โ Mutual Evaluation Report โ September 2015
Ratings โ Effectiveness (2/3)
Immediate outcome of an effective system to combat money
laundering (ML) and terrorist financing (TF)
Extent to which
Vanuatu has
achieved this
objective
5 Legal persons and arrangements are prevented from misuse
for money laundering or terrorist financing, and information
on their beneficial ownership is available to competent
authorities without impediments.
Low
6 Financial intelligence and all other relevant information are
appropriately used by competent authorities for money
laundering and terrorist financing investigations.
Low
7 Money laundering offences and activities are investigated
and offenders are prosecuted and subject to effective,
proportionate and dissuasive sanctions.
Low
8 Proceeds and instrumentalities of crime are confiscated. Low
3
4. Anti-money laundering and counter-terrorist financing measures in Vanuatu โ Mutual Evaluation Report โ September 2015
Ratings โ Effectiveness (3/3)
Immediate outcome of an effective system to combat money
laundering (ML) and terrorist financing (TF)
Extent to which
Vanuatu has
achieved this
objective
9 Terrorist financing offences and activities are investigated
and persons who finance terrorism are prosecuted and
subject to effective, proportionate and dissuasive sanctions.
Low
10 Terrorists, terrorist organisations and terrorist financiers are
prevented from raising, moving and using funds, and from
abusing the non-profit sector.
Low
11 Persons and entities involved in the proliferation of
weapons of mass destruction are prevented from raising,
moving and using funds, consistent with the relevant United
Nations Security Council Resolutions.
Low
4
5. Anti-money laundering and counter-terrorist financing measures in Vanuatu โ Mutual Evaluation Report โ September 2015
Ratings โ Effectiveness
5
00
11
High
Substantial
Moderate
Low
6. Anti-money laundering and counter-terrorist financing measures in Vanuatu โ Mutual Evaluation Report โ September 2015
Ratings โ technical compliance (1/5)
19-Oct-15
6
AML/CFT POLICIES AND COORDINATION
1. Assessing risks & applying a risk-based approach NNNN Non compliant
2. National cooperation and coordination NNNN Non compliant
MONEY LAUNDERING AND CONFISCATION
3. Money laundering offence NNNN Non compliant
4. Confiscation and provisional measures P P P P Partially compliant
TERRORIST FINANCING AND FINANCING OF PROLIFERATION
5. Terrorist financing offence P P P P Partially compliant
6. Targeted financial sanctions related to terrorism & terrorist financing P P P P Partially compliant
7. Targeted financial sanctions related to proliferation NNNN Non compliant
8. Non-profit organisations NNNN Non compliant
7. Anti-money laundering and counter-terrorist financing measures in Vanuatu โ Mutual Evaluation Report โ September 2015
Ratings โ technical compliance (2/5)
19-Oct-15
7
PREVENTIVE MEASURES
9. Financial institution secrecy laws LaLaLaLa Largely compliant
Customer due diligence and record keeping
10. Customer due diligence P P P P Partially compliant
11. Record keeping LaLaLaLa Largely compliant
Additional measures for specific customers and activities
12. Politically exposed persons LaLaLaLa Largely compliant
13. Correspondent banking LaLaLaLa Largely compliant
14. Money or value transfer services P P P P Partially compliant
15. New technologies LaLaLaLa Largely compliant
16. Wire transfers NNNN Non compliant
8. Anti-money laundering and counter-terrorist financing measures in Vanuatu โ Mutual Evaluation Report โ September 2015
Ratings โ technical compliance (3/5)
19-Oct-15
8
PREVENTIVE MEASURES (continued)
Reliance, Controls and Financial Groups
17. Reliance on third parties NNNN Non compliant
18. Internal controls and foreign branches and subsidiaries NNNN Non compliant
19. Higher-risk countries P P P P Partially compliant
Reporting of suspicious transactions
20. Reporting of suspicious transactions LaLaLaLa Largely compliant
21. Tipping-off and confidentiality LaLaLaLa Largely compliant
Designated non-financial Businesses and Professions (DNFBPs)
22. DNFBPs: Customer due diligence P P P P Partially compliant
23. DNFBPs: Other measures P P P P Partially compliant
9. Anti-money laundering and counter-terrorist financing measures in Vanuatu โ Mutual Evaluation Report โ September 2015
Ratings โ technical compliance (4/5)
19-Oct-15
9
24. Transparency and beneficial ownership of legal persons NNNN Non compliant
25. Transparency and beneficial ownership of legal arrangements NNNN Non compliant
POWERS AND RESPONSIBILITIES OF COMPETENT AUTHORITIES AND OTHER INSTITUTIONAL MEA
Regulation and Supervision
26. Regulation and supervision of financial institutions P P P P Partially compliant
27. Powers of supervisors P P P P Partially compliant
28. Regulation and supervision of DNFBPs P P P P Partially compliant
Operational and Law Enforcement
29. Financial intelligence units LaLaLaLa Largely compliant
30. Responsibilities of law enforcement and investigative authorities CCCC Compliant
31. Powers of law enforcement and investigative authorities P P P P Partially compliant
32. Cash couriers LaLaLaLa Largely compliant
TRANSPARENCY AND BENEFICIAL OWNERSHIP OF LEGAL PERSONS AND ARRANGEMENTS
10. Anti-money laundering and counter-terrorist financing measures in Vanuatu โ Mutual Evaluation Report โ September 2015
Ratings โ technical compliance (5/5)
19-Oct-15
10
General Requirements
33. Statistics NNNN Non compliant
34. Guidance and feedback P P P P Partially compliant
Sanctions
35. Sanctions P P P P Partially compliant
INTERNATIONAL COOPERATION
36. International instruments P P P P Partially compliant
37. Mutual legal assistance P P P P Partially compliant
38. Mutual legal assistance: freezing and confiscation NNNN Non compliant
39. Extradition P P P P Partially compliant
40. Other forms of international cooperation NNNN Non compliant
POWERS AND RESPONSIBILITIES OF COMPETENT AUTHORITIES AND OTHER INSTITUTIONAL
MEASURES (continued)
11. Anti-money laundering and counter-terrorist financing measures in Vanuatu โ Mutual Evaluation Report โ September 2015
Ratings โ technical compliance
11
1
9
17
13 Compliant
Largely compliant
Partially compliant
Non compliant