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Iceland’s Anti-Money Laundering and Counter-Terrorist Financing Efforts Under Scrutiny
A recent report has highlighted concerns over the lack of coordination between authorities and the private sector in Iceland’s efforts to combat money laundering (ML) and terrorist financing (TF). Despite having a good legal framework, Iceland’s implementation of anti-money laundering and counter-terrorist financing measures is plagued by a lack of consistency and understanding.
Coordination Issues
The report notes that Icelandic authorities have only recently begun to coordinate their efforts in the context of ML/TF, and even then, it has been limited to preparing a National Money Laundering and Terrorist Financing Risk Assessment (NRA). However, this assessment was not widely disseminated to the private sector, leaving many financial institutions without guidance on how to identify and mitigate ML/TF risks.
- No overarching strategy or mechanism in place for domestic coordination at the ministerial level or among competent authorities.
- Limited coordination has a negative impact on Iceland’s entire AML/CFT regime.
Financial Intelligence Unit (FIU) Challenges
- FIU officials have access to a wide range of information, including public databases and police records, but they do not have access to beneficial ownership information or information related to non-profit organizations.
- While FIU officials perform operational analysis, they lack strategic analysis products that would help them understand ML trends and methods in Iceland.
Asset Tracing and Seizure
- Concerns over the country’s ability to trace and seize the proceeds of crimes, both domestically and abroad.
- Law enforcement authorities show a high level of commitment to tracing and seizing assets, but there is no coordination or awareness among authorities about the increased risk of cross-border transportation or movements of currency.
Terrorist Financing
- No criminal investigations or prosecutions in Iceland, despite effective cooperation with other countries’ security services.
- Intelligence was shared with other countries in which active investigations were initiated, but there appears to be a lack of consideration of TF vulnerabilities in Iceland by law enforcement agencies.
Targeted Financial Sanctions (TFS)
- Lack of clarity among competent authorities on the legal framework for implementing TFS and the freezing obligation in Iceland.
- This has resulted in TFS not being implemented without delay, as required under UN Security Council resolutions.
- Supervisory authorities do not monitor or ensure compliance with TFS for TF and proliferation financing (PF).
- Low level of awareness among designated non-financial businesses and professions (DNFBPs) and certain financial institutions (FIs) of their responsibilities related to TFS for PF, and to a lesser extent, for TF.
Conclusion
While Iceland has made some progress in implementing anti-money laundering and counter-terrorist financing measures, there is still much work to be done to ensure the effectiveness of these measures.