Title: Major Money Laundering Probe Underway in Croatia: Role of the Anti-Money Laundering Office (AMLO)

Background

Amid growing concerns over money laundering activities in Croatia, the Anti-Money Laundering Office (AMLO) has taken the lead in investigations. This central national body, under the Ministry of Finance, plays a pivotal role in collecting, analyzing, and disseminating Anti-Money Laundering/Countering the Financing of Terrorism (AML/CTF) data to competent authorities.

AMLO Key Information

Director: Ante Biluš Address: Ulica grada Vukovara 72, 10000 Zagreb Contact: tel: ++385 1 6345 455, fax: ++385 1 6345 452, info@amlo.hr

Role and Responsibilities of the AMLO

The AMLO performs several critical activities regarding money laundering and terrorist financing (ML/TF) investigations, in line with international standards.

1. Analyzing intelligence: Analyzes suspicious transactions and, upon establishing ML/TF suspicions, disseminates cases to competent authorities like the State Attorney’s Office, Police, and supervision bodies.
2. Inter-institutional cooperation: Cooperates with key government bodies, such as the State Attorney’s Office, Ministry of the Interior (General Police Directorate), Ministry of Finance’s supervisory services, Croatian Financial Services Supervision Agency, Croatian National Bank, Security-Intelligence Agency, Ministry of Foreign Affairs, and Ministry of Justice.
3. Data exchange: Exchanges vital data, information, and documentation with foreign Financial Intelligence Units (FIUs) and other international organizations.
4. Preventive measures: Acts proactively through off-site administrative supervision and educational programs to report entities.
5. Public information: Keeps the public updated on current ML/TF techniques, methods, trends, and typologies through various means.

AMLO and Croatian Legislation

• Established under the Anti-Money Laundering and Terrorist Financing Law (AMLTF Law).
• Annual report on AMLO’s work is submitted to the Croatian Government by the Ministry of Finance.
• Croatian Parliament adopted new AMLTF Law in 2017, aligning the country’s legislation with the EU’s 4th Anti-Money Laundering Directive and FATF Recommendations.

Organizational Structure

• Three primary units:
  1. Service for Financial Intelligence Analytics: a. Department for Suspicious Transactions b. Department for Strategic Analysis and Information System
  2. Service for Prevention and Supervision of Reporting Entities: a. Department for Financial and Non-financial Institutions b. Department for Inter-Institutional and International Cooperation

ML/TF Prevention System

The ML/TF prevention system in Croatia outlines the roles and responsibilities of various institutions. The AMLO is a crucial link, enabling efficient cooperation to prevent the financial system from being used for ML/TF purposes.

Alongside the AMLO, key components of the prevention system include reporting entities, supervisory bodies, law enforcement agencies (LEAs), and prosecutors’ offices.

Reporting Entities

Reporting Entities, as per Article 4 (2) of the AMLTF Law, include banks, savings banks, credit unions, authorized exchange offices, insurance companies, game organizers, brokerages, lawyers, notaries public, tax advisors, and others.

Key Components of the ML/TF Prevention System

1. Reporting Entities: Report suspicious transactions to the AMLO.
2. Supervisory Bodies: Ensure compliance with the Law.
3. AMLO: Analyzes reported cases and disseminates to competent authorities.
4. LEAs: Conduct police inquiries and financial investigations.
5. Prosecution: Directs the work of LEAs in ML/TF cases and coordinates between competent bodies.
6. Courts: Conduct criminal proceedings for ML/TF offenses and confiscation of proceeds.