In a new report MONEYVAL encourages the Holy See (including the Vatican City State) to further strengthen measures to combat money laundering and financing of terrorism. The Council of Europe’s anti-money laundering body draws up a comprehensive assessment of the country’s level of compliance with the Recommendations by the Financial Action Task Force (FATF).
The report states that the jurisdiction’s authorities have a generally good high-level understanding of their money laundering and financing of terrorism threats and vulnerabilities. In fact, in a range of areas, there is a detailed understanding of risk. However, domestic cases which have raised a red flag for potential abuse of the internal system by mid-level and senior figures (insiders) for personal or other benefits have not been addressed within the national risk assessment.
MONEYVAL notes that money laundering investigations during the period under review (until October 2020) were protracted, partly because of late responses from foreign counterparts to requests for assistance and partly because of under-resourcing on both prosecutorial and law enforcement sides, where there has been insufficient specialisation of financial investigators. Consequently, results in court have been modest with only two convictions for self-laundering. Recent developments highlighted in the report in this area are encouraging.
The report highlights as well the importance given to confiscation as a policy objective, which is illustrated by the adoption in 2018 of a robust framework for non-conviction-based confiscation - which has since been used in a high-profile case. Although the competent authorities are tracing and seizing proceeds effectively, there is a considerable gap between the amounts seized and those confiscated.
The Holy See (including the Vatican City State) has a domestic mechanism in place that allows to give effect to United Nations’ sanctions without undue delay. However, some delays persist in transposing such designations into national lists.