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Strengthening Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) Measures in Korea
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Key Points
Korea’s institutional framework for anti-money laundering (AML) and counter-terrorist financing (CFT) measures has several key points that need attention.
- Institutional Framework: Korea’s institutional and supervisory framework is complex, but entrusted agencies have excellent cooperation and coordination.
- DNFBPs not subject to AML/CFT: Except for casinos, designated non-financial businesses and professions (DNFBPs) are not subject to the AML/CFT framework or supervised.
- Casinos’ rules-based supervision: The supervisor of casinos in Korea’s self-governing province takes a rules-based approach to supervision.
- Supervision by KoFIU and FSS: Supervision by the Korean Financial Intelligence Unit (KoFIU) and the Financial Supervisory Service (FSS) would benefit from increased resources.
- Remedial actions: Supervisors take remedial actions through administrative or monetary sanctions, which are effective but not fully proportionate.
- Guidance and outreach: KoFIU has been active in providing guidance and outreach to supervised sectors, but needs to issue targeted terrorist financing (TF) guidance.
- Legal persons: Korea has a growing understanding of the ML/TF risks associated with legal persons, but authorities do not yet have a clear understanding of why these entities are particularly vulnerable.
- Complex corporate structures: LEAs reported seeing an increased use of complex typologies involving corporate structures in both ML and predicate offense cases.
- Basic and legal ownership information: Basic and legal ownership information on legal persons is publicly available through a comprehensive network of registries, but information may not always be accurate or up-to-date.
Recommendations
To strengthen Korea’s AML/CFT framework, the following recommendations are made:
- Extend AML/CFT framework to DNFBPs: Extend the AML/CFT framework to apply to all designated non-financial businesses and professions (DNFBPs) and designate a supervisor for these sectors.
- Include domestic PEPs and international organisation PEPs: Expand the scope of AML/CFT obligations to include domestic politically exposed persons (PEPs) and PEPs of international organisations.
- Amend tax crimes as ML predicate offenses: Amend the law to expand the range of tax crimes that are money laundering (ML) predicate offenses, aligning this range with those that require suspicious transaction report (STR) reporting.
- Promote asset recovery: Continue exploring measures to promote the actual recovery of assets ordered for confiscation and systematically take enforcement actions.
These recommendations aim to strengthen Korea’s AML/CFT framework, improve supervision, and enhance international cooperation to combat money laundering and terrorist financing.