Here is the converted article in markdown format:

Lack of Transparency in Money Laundering and Terrorist Financing Cases Raises Concerns

The recent Instruction issued by the National Coordination Committee for Anti-Money Laundering and Counter-Financing of Terrorism has sparked controversy among experts, who argue that it lacks transparency and raises concerns about the effectiveness of the country’s efforts to combat money laundering and terrorist financing.

Prioritizing Secrecy Over Transparency

The Instruction, which outlines the procedures for prosecution, collection of statistics, and enforcement of judgments in cases related to money laundering and terrorist financing, seems to prioritize secrecy over transparency. For example:

• Article 16 states that legal proceedings conducted by courts shall be done in compliance with certain sections of the Law on Criminal Procedure, but fails to provide clear guidelines on how these procedures will be implemented.
• Article 21 requires the issuance of an order on taking a final judgment on money laundering and terrorist financing for enforcement, but does not specify the criteria or procedure for issuing such an order.

This lack of transparency raises concerns about the potential for abuse or manipulation of the system.

Effectiveness of Measures in Question

Experts have also questioned the effectiveness of the Instruction’s measures to prevent money laundering and terrorist financing. For example:

• Article 19 requires courts to adjudicate on the determination of penalties for predicate offenses and offenses related to money laundering and terrorist financing in a detailed and accurate manner. However, it does not specify how these penalties will be enforced or monitored.

Call for Additional Investigation

In light of these concerns, we urge the National Coordination Committee to conduct additional investigation into the implementation of this Instruction. We also call on relevant authorities to provide clear guidelines on key issues and to ensure transparency in the prosecution and enforcement of judgments related to money laundering and terrorist financing.

Public Has a Right to Know

The public has a right to know how their tax dollars are being spent to combat these serious crimes, and it is essential that those responsible for implementing these measures be held accountable. We hope that the National Coordination Committee will take our concerns seriously and work towards creating a more transparent and effective system to prevent money laundering and terrorist financing.

Additional Recommendations

1. The National Coordination Committee should provide clear guidelines on key issues related to the implementation of this Instruction.
2. Relevant authorities should ensure transparency in the prosecution and enforcement of judgments related to money laundering and terrorist financing.
3. The public should be informed about the progress made in combating money laundering and terrorist financing, including the results of investigations and prosecutions.

We hope that by taking these steps, we can create a more effective and transparent system to prevent money laundering and terrorist financing.