How much do APAC’s regulators earn?

Regulators’ salaries across Asia Pacific vary enormously:some supervisors earn fortunes and others hit the pay scale at the average to low end.APAC REGULATORs - SALARIES

Some governments believe that paying politicians and civil servants high salaries should reduce the likelihood of them accepting a bribe, offered in cash or disguised as a gift. Others argue that financial regulators will be less likely to jump ship and work for a bank if they are paid competitively by the government. Some countries pay their banking regulators on the same modest scale as other government employees , pitting them against some of the highest paid people in the country – bankers.

Last April, we found out how much the head of the Hong Kong Monetary Authority brings home; Norman Chan Tak-lam was set to earn HKD$9.41m(USD1.2m), making him the highest paid central bank chief in the world.  As the HKMA is also the banking regulator, this makes Chan Tak-lam the biggest earning regulator in the world. Chan Tak-lam’s counterpart in Beijing, Shang Fulin, the head of China Banking Regulatory Commission, earns an estimated  CNY11,271 (USD1,800) per month.

The accompanying infographic details more of APAC banking regulators’ earnings.

Comparing regulators salaries with those of bankers reveals a stark difference. Since the global financial crisis took hold in 2008, we have seen a distinct change of attitude towards financial institutions. Blatant rule breaking by banks – whether money laundering, sanctions busting or tax evasion – is being punished in high-profile cases as regulators finally start to show their teeth. However, the impact on the individuals responsible have been unremarkable; a move to a less high-profile role in the bank, or early retirement as opposed to job loss or, as some have called for, criminal prosecution.

Rather than going after the bankers who allowed criminality to go unchecked at banks, or those who made good from the financial crisis, there is an element of maintaining the status quo vis a vis bankers’ salaries that is out of step with the movement to make change for the better in the financial sector.

In the post global financial crisis and post public bailout economy, can banks justify paying million dollar bonuses?

In February 2015, Ross McEwen, the head of RBS, went on record to defend bonuses for bankers in spite of government bailouts and losses:

“I need to be fair paying for our people so I can actually keep them onboard.”

Although McEwen has opted to hand back his personal GBP1m (USD1.5m) share award to the bank he will still take home an expected GBP2.7m (USD4m) in 2015. Peter Sands, the outgoing boss of Standard Chartered also waived his bonus in 2015.

Looking at Asia Pacific, four of China’s largest five banks made the Banker’s Almanac list of top ten biggest financial institutions. This includes Industrial and Commercial Bank of China, China Construction Bank Corporation, Agricultural Bank of China Limited and Bank of China. China Development Bank Corporation languished at no. 21 on the list.

“According to the half-year annual reports of the listed commercial banks, the average annual payment before deductions for the chairmen of the five biggest Chinese commercial banks was around 2 million yuan ($325,600).”Source:The Global Times 2014.

Piyush Gupta, CEO of DBS bank, Singapore’s largest, made SGD9.2m (USD 6.6m)
The CEOs of United Overseas Bank and Oversea Chinese Banking Corporation were not far behind.

Chief regulators salaries fall far short of those earned by their peers at regulated entities.
It’s unlikely they will ever be measured on the same scale. Regulators, in an ideal world, would be motivated by doing the right thing for the right reasons. That is certainly the message that some regulators are putting across. But banking is all about money, and the more you earn, the higher your status.

First published on the International Compliance Association blog in March 2015. 


What messages are bribery settlements sending out to would be briber givers and receivers?

Influential, wealthy and ‘lawyered-up’ entities are settling bribery cases with prosecutors by throwing money at the case in order to avoid admitting guilt or proving innocence. What message does this send out to the world?

Smith & Wesson, a US handgun manufacturer, agreed to pay a USD2m fine to the Securities and Exchange Commission this week to settle FCA- cartoonsmoking gunallegations of bribery. The SEC charged Smith & Wesson with breaching the Foreign Corrupt Practices Act when employees and representatives made improper payments to foreign officials in Indonesia and Pakistan to secure contracts. Further alleged attempts at the same in Bangladesh, Nepal and Turkey, failed. S&W has neither admitted nor denied the allegations, it just paid to make it go away.

In a non-Asian related case, reports in the press claim that Bernie Ecclestone’s legal team is trying to settle a bribery case by paying GBP20m in return for the charges to be dropped, reported The Telegraph.

Meanwhile in Laos, where corrupt politicians are accepting bribes from Vietnamese‘land-grabbers’ to uproot communities whose homes are on the land.  The Laotian communities have no resources to fight a case, so they deal with the awful consequences of losing their homes.

Over in Australia, a court issued a suppression order (aka a super-injunction) prohibiting anyone in the country from mentioning details related to a multi-million dollar bribery probe implicating public officials from Indonesia, Malaysia and Vietnam. Wikileaks chose to publish the order which reveals how the case reaches to the highest echelons of Asia-Pacific’s leadership. The order follows the indictment of seven employees from the Reserve Bank of Australia, who, by nature of their work are politically exposed persons. ‘National security’ is cited as the reason for the blanket ban.

Australia and the US are in the top 20 group of least corrupt countries in the world, as per Transparency International’sCorruption Perceptions Index 2013. Malaysia and Turkey linger mid table while Bangladesh, Indonesia, Nepal and Pakistan are all between 100-150 out of 175. Laos is in the same group. The jurisdictions who are perceived to be the most corrupt have fewer defences available to protect themselves from unscrupulous bribe offerers. Sure, the public officials offered money in exchange for using their political clout could always say no, but why should they when the messages coming from their less corrupt peers is to buy your way out of it?

There is always time to celebrate anti-corruption efforts. The Global Organisation of Parliamentarians Against Corruption (GOPAC) has launched an award for anti-corruption action. Cast your votes before October 31st here.

This article first appeared on the International Compliance Association blog.

Australia bans reporting on corruption case, launches new ant-graft centre

The Australian Federal Police are the proud new leaders of a national anti-corruption centre. According to The AustralianThe Fraud and Anti-Corruption Centre, to be announced today, involves officials from government agencies including the tax office, Customs, Defence and the Department of Foreign ­Affairs and Trade working alongside federal police officers. FCA - Australiaflag

Meanwhile, another branch of the Australian executive has ‘blindfolded’ the Australian public by placing a super-injunction on a multi-national corruption case. The Supreme Court of the state of Victoria has banned Australian media organisations from reporting on the case which reportedly involves officials from Malaysia, Indonesia, Vietnam. The gag follows the secret indictment seven senior executives from subsidiaries of Australia’s central bank, the Reserve Bank of Australia (RBA), Wikileaks reported.

“The case concerns allegations of multi-million dollar inducements made by agents of the RBA subsidiaries Securency and Note Printing Australia in order to secure contracts for the supply of Australian-style polymer bank notes to the governments of Malaysia, Indonesia, Vietnam and other countries.”

The suppression order in full is here.

SEC hits Smith and Wesson with USD2m FCPA settlement

The US Securities and Exchange Commission (SEC) has agreed to accept a USD2m payment from gun manufacturer Smith and Wesson to settle charges of violating the Foreign Corrupt Practices Act (FCPA).  As per the SEC’s investigations, the firm made slightly more than USD100,000 on one deal, and lost other sums when deals they had set up fell through and the recipients took the gifts but never signed a contract. The deals happened in various Asian countries. It is worth noting that by accepting this deal, the firm has consented to the settlement without admitting or denying the findings of the inquiry. In the breakdown, Smith and Wesson – described as a medium sized firm taking high risks – paid USD1.96m to the SEC in a penalty, with the remainder repaid in the profit they made (known as disgorgement) and in prejudgement interest. FCA - Smith and Wesson

According to the SEC statement, the firm:

  • Profited by more than $100,000 from the one contract that was completed
  • Sought to break into new markets overseas starting in 2007 and continuing into early 2010.
  • International sales staff engaged in a pervasive effort to attract new business by offering, authorizing, or making illegal payments or providing gifts meant for government officials in Pakistan, Indonesia, and other foreign countries.
  • Retained a third-party agent in Pakistan in 2008 to help the company obtain a deal to sell firearms to a Pakistani police department.
  • Authorized the agent to provide more than $11,000 worth of guns to Pakistani police officials as gifts, and then make additional cash payments.  Smith & Wesson ultimately won a contract to sell 548 pistols to the Pakistani police for a profit of $107,852.
  • Lost their bribe money in Indonesia when a deal brokered with a third-party agent and the Indonesia police department fell through.
  • Authorized improper payments to third-party agents who indicated that portions would be provided to foreign officials in Turkey, Nepal, and Bangladesh.  The attempts to secure sales contracts in those countries were ultimately unsuccessful.

A quick note on arms brokers 

I cannot be sure that arms deal brokers, or third parties, all share a defining set of characteristics which may provide enough data to make a meaningful profile in a transaction monitoring system, but here is an account from my experience. I met one arms broker in Asia a few years ago who freely admitted to acting as a mediator between arms companies and several African countries. As an ex-armed forces officer, his support on a deal carried weight. His job was to attend lavish parties, socialise with and befriend embassy officials to make a pathway for the eventual deal. He declined to let me meet his boss, who was under investigation back then and was arrested along with his wife not so long ago on bribery related charges. While boss and his wife are still languishing in one of Asia’s most notorious jails, I am not sure what happened to the befriending broker.

Corruption: Does my bung look big in this?

In March, the US Department of Justice has slapped a USD88m fine on Japanese firm Marubeni for their involvement in a seven-year campaign to bribe high ranking FCA - US DOJIndonesian members of parliament and other public officials. The DOJ account of how the bribes were orchestrated sheds some light on the process. One of the most amusing elements of the case reveals how deep-seated bribery and corruption plays out in the meeting rooms of corporations, using specially drafted consultants to manage the deals and how officials react when they feel they are being short-changed.

The first ‘graft’ consultant was offered three per cent of the total deal in commission, for feeding the appropriate hands in parliament and at state-owned companies. The bribe-takers, in this case officials at the national power company, griped that their gifts might not be substantial enough to secure their favour and when word of their unhappiness reached the right ears, his commission was reduced to one per cent and a second ‘graft’ specialist was brought in to seal the deal. This is how bribes are made – no brown envelopes, nothing is under the counter. It is open, documented and built into the budget.

The DOJ used the extra-territorial provisions of the Foreign Corrupt Practices Act to target the firm. Marubeni pleaded guilty to eight charges – read the full DOJ report here


Repercussions for the firm extend far beyond the dollar fine. Marubeni is subject to investigation by the Federal Bureau of Investigations, and the presence of the agents alone around the US offices is enough to cause concern for future clients.

Damage to its reputation could have a significant effect on future business, allowing the competition to step in and win contracts based on the fact that they are not on the receiving end of a DOJ penalty and probe.

Last but by no means least, comes the remedial action the firm must take, as dictated by the terms of their plea agreement. This is the real meat for Governance, Risk and Compliance professionals.

Marubeni has agreed to maintain and implement an enhanced global anti-corruption compliance program and to cooperate with the department’s ongoing investigation. This will be a large cost to the firm. The agreement also highlights the apparent lack of an effective ‘compliance and ethics program’ as a factor in the final plea agreement.

Regrettably for Marubeni, all of its dirty dealings were recorded in emails which detail conversations between consultants and Marubeni, including percentages to be paid in commissions.

Two former executives have pleaded guilty to FCPA breaches and two more face charges.

A consortium of failures

Some of the failings noted in the DOJ final notice.

Two senior executives,, both in sales’ positions, have pleaded guilty to conspiracy to breach the FCPA.

Allegations of bribery were laid against two more executives in July 2013; by March 2014, these allegations were not proven.

According to court filings, Marubeni, its employees, and other parties paid bribes to officials in Indonesia for assistance in securing a USD118m contract, known as the Tarahan project. The contract was for Marubeni and its consortium partner to provide power-related services for the citizens of Indonesia.

The bribe-takers included a high-ranking member of the Indonesian Parliament, senior members of Perusahaan Listrik Negara (PLN), the state-owned and state-controlled electricity company.

The two consultants hired in connection with the Taharan project to provide legitimate consulting services were, according to the DOJ, taken on to pay bribes to Indonesian officials.

Does my bung look big in this?

E-mails between employees at the Marubeni subsidiary in Indonesia gave details of the bribery system and concerns or demands of the bribe takers.

Officials from the state power company expressed ‘concern’ about whether the agent FCA - Pocket moneywould provide them with satisfactory ‘rewards’ or maybe her would ‘only give them pocket money and disappear.’ Clearly, the bent state-employees of Indonesia can see when their own warped integrity could be devalued. Comments that the agent has not shown he was ‘willing to spend money’ might even suggest that, radically, he was not prepared to offer enormous bribes.

Either way, he lost the gig. A mail sent by Marubeni employees stated the following: “unfortunately our agent almost did not execute his function at all, so far. In case we don’t take immediate action now now [sic], we don’t have any chance to get this project forever.”

The first graft consultant still got his one per cent commission, even though a second bribe expert was brought in to close the deal, on the remaining two per cent commission.

The report concludes with this comment:

“Marubeni and its co-conspirators were successful in securing the Tarahan project and subsequently made payments to the consultants for the purpose of bribing the Indonesian officials. Marubeni and its co-conspirators paid hundreds of thousands of dollars into the first consultant’s bank account in Maryland to be used to bribe the member of Parliament. The consultant then allegedly transferred the bribe money to a bank account in Indonesia for the benefit of the official.”

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Rolls-Royce bolsters ethics policy in face of corruption probe

(Reuters) – Aerospace and defence company Rolls-Royce (RR.L), facing an investigation by Britain’s anti-fraud watchdog, said it had cut the number of middlemen it uses as it steps up efforts to prevent bribery and corruption. FCA - RollsRoycePOverty

The British company said in its annual report on Wednesday that as well as cutting down on the number of intermediaries it uses, it has relaunched a 24-hour ethics telephone line for staff and created a new role of head of risk training.

The world’s second-largest maker of aircraft engines said in December the Serious Fraud Office (SFO) had launched a formal investigation into concerns of possible bribery and corruption in China and Indonesia.

A year earlier, it had passed information to the SFO relating to bribery and corruption involving intermediaries in overseas markets, and said it could face prosecution.

Rolls-Royce is also facing an investigation into state-run Hindustan Aeronautics Ltd‘s (HAL) orders from Rolls-Royce.

Investigations over overseas corruption and bribery are a perennial risk facing makers of military equipment, given the huge contracts and high secrecy in the defence sector.

Rolls-Royce tasked lawyer David Gold with leading a review of its compliance procedures after the allegations emerged. He published his interim report in July. A final version is expected in due course.

“The number of intermediaries used by our businesses has continued to fall dramatically during the year,” Rolls said in its annual report, adding that it was working to simplify its anti-bribery policies in line with Gold’s recommendations.

Rolls-Royce said last month that U.S. and European spending cuts would halt profit growth in 2014, bringing to an end the group’s decade-long record of increasing annual profits.

A pay freeze for top management will accompany the group’s gloomier outlook for this year.

“There will be no increase in basic pay for most of the senior leadership team in 2014,” the company said.

Rolls’s performance over the previous three years was, however, strong enough to trigger rewards under a long term incentive plan.

The group’s chief executive John Rishton earned a total of 6.2 million poundsin 2013, 36 percent higher than the 4.6 million pounds he took home the year before on account of the payout.

(Reporting by Sarah Young, editing by Louise Heavens)

Source: Reuters

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Indonesia: Court reveals Akil’s bribery record

The Jakarta Corruption Court has revealed the extent of bribery involving Akil Mochtar during a graft FCA - graft and corruption fistcase in which the former Constitutional Court chief justice appeared as defendant. The alleged bribery exposed in the case included names and other details relating to 15 regional election disputes.

According to the court, Akil accepted Rp 3 billion (US$255,450) in bribes from Gunung Mas Regent Hambit Bintih, through Golkar lawmaker Chairun Nisa. On a different occasion, Akil was promised Rp 1 billion from one of his sidekicks, lawyer Susi Tur Andayani, to issue a ruling in favor of Amir Hamzah and Kasmin, contenders in the Lebak regency election. The money was from Tubagus Chaeri “Wawan” Wardana.

Prosecutors also managed to find evidence that Akil had accepted bribes of Rp 7.5 billion from Wawan to settle the Banten governor election dispute in favor of Ratu Atut.

On another occasion, evidence has revealed that Susi Tur Andayani forwarded Rp 500 million of “success fees” to Akil after he ruled in favor of Rycko Menoza and Eki Setyanto, who had been elected as South Lampung regent and deputy regent.

Akil was also found to have accepted Rp 10 billion and US$500,000 for fixing the Empat Lawang regency election through Muhtar Ependy. Also through Muhtar Ependy, Akil was reported to have accepted Rp 19.8 billion in bribes to ensure the win of the Romi Herton-Harno Joyo ticket at the Palembang mayor elections.

Furthermore, reported that Akil had accepted Rp 1 billion to settle the Buton regency dispute.

The court saw further evidence that Akil had accepted Rp 2.9 billion to settle disputes relating to the Morotai Island regency elections. Additionally, Akil accepted Rp 1.8 billion from Raja Bonaran Situmeang, a former lawyer who won the seat of Central Tapanuli regent.

The court was presented with further evidence revealing that Akil had requested Rp 125 million as a “consultation fee” from Papua Deputy Governor Alex Hesegem. Akil had been promised Rp 10 billion in bribes from incumbent Soekarwo during the East Java governor election dispute.

Akil, former Golkar Party politician, has been charged with multiple offences and could be sentenced to a maximum of 20 years in prison. (tjs/dic)

Source: The Jakarta Post

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Indonesia: Bribes expected to increase as elections near

Indonesia’s anti-corruption agency predicted an increase in graft in the run-up to elections this year, with its vice chairman FCA - bribesanticipating the rise will land major cases on the authority’s books.

Corruption usually escalates around elections as officials take advantage of their posts by trading favors and candidates seek to fund campaigns, Adnan Pandu Praja, vice chairman at the Corruption Eradication Commission, or KPK, said in an interview in Jakarta yesterday. Parliamentary elections are scheduled for April and a presidential ballot in July.

The KPK, which has already caught government ministers, chief executives and central bankers, is still scratching the surface of the 7,000 reports of graft it gets from across the archipelago of the world’s fourth-most populous nation each year, Praja said. Indonesia ranked 114th among 177 countries in a 2013 Transparency International survey on corruption perceptions, undermining the country’s investment appeal.

“There will be a big fish in the pipeline,” Praja said, with several others in the “tank” to be announced in the next six months. Praja did not give specifics, citing the sensitivity of the KPK’s investigations. “Corruption runs from the east to the west, from the west to the east.”

The agency has prosecuted 72 members of parliament, eight government ministers, six central bankers, four judges and dozens of CEOs in the decade since it was formed in 2003 and boasts a 100 percent conviction rate.


The agency has convicted three foreigners, one from Japan and two from Malaysia. This number is low partly because overseas executives are worried about strict U.S. and British laws on graft overseas, which can land them in jail, and also because foreigners avoid giving bribes directly, he said.

“They have a strategy to avoid the act, by using a third party to do it,” Praja said.

The KPK’s strategy is to tap suspects’ phones and follow the money trail to try to catch people red-handed, Praja said. The agency’s efforts have made people more careful and secretive about being corrupt, he said.

The agency will focus on tackling graft in government revenue, energy and food security this year, Praja said. It’s starting to investigate potential corruption stemming from a Jan. 12 ban on exports of mineral ores such as nickel and bauxite, he said.

Rigged System

The KPK has done a good job in arresting officials with limited resources, said Fauzi Ichsan, a managing director and head of government relations at Standard Chartered Plc in Jakarta. Companies selling goods and services, such as autos and banking, can operate cleanly, while energy and mining are industries where graft is common, he said.

“The system is rigged to the extent that the opportunities for corruption are pretty widespread,” Ichsan said in an interview yesterday. For investors, projects can be stopped by requests for bribes coming from many people, even when they don’t necessarily get things done, he said.

President Susilo Bambang Yudhoyono, who is ineligible to run after his second term ends this year, was re-elected in 2009 on a platform to fight corruption.

The KPK will urge presidential candidates in June to have an anti-graft vision and develop a cleaner government as part of their campaign promises in an effort to make them more accountable, Praja said.

“All political parties seem involved,” Praja said. “There’s always money involved when they make campaigns.”

Strong President

A strong president is also needed to curb corruption among lawmakers, who have in the past opposed efforts by the KPK, he said. “If the executive has enough confidence to fight against parliamentary pressure, then bit by bit parliament will learn.”

The KPK plans to initiate discussions on avoiding graft in each parliamentary commission, where bills are debated, after the April elections, Praja said.

Jakarta Governor Joko Widodo, who has not announced whether he will run for president, topped a poll by the Indonesian Survey Circle carried out in January, attracting as much as 35.6 percent support from respondents. Coal tycoon Aburizal Bakrie, of the Golkar party, was second with 20.1 percent and the Gerindra party’s Prabowo Subianto, a former army general, was third with 19.7 percent support.

Praja said regional mayors emerging on the national scene are supporting the fight against corruption, including Widodo and Tri Rismaharini, the mayor of Surabaya, Indonesia’s second-largest city.

Widodo’s efforts to take on parliament over the administration’s budget were “inspiring,” he said. Widodo said in an interview last month that he has moved budget procurement and tax collection online in an effort to cut graft.

“Most Indonesians are probably grateful that something has been done on the issue in recent years, and that the KPK has played the dutiful role of a lonely warrior in a protracted quest,” said Wellian Wiranto, a Singapore-based economist at Oversea-Chinese Banking Corp. “Ironically, however, the more they dig, the more cases might be unveiled, contributing to the sense that corruption remains a rather prevalent issue.”

To contact the reporter on this story: Neil Chatterjee in Jakarta at

To contact the editor responsible for this story: Rosalind Mathieson at

Indonesian AML and counter terrorist financing efforts

In February, the Financial Action Task Force placed Indonesia on its list of jurisdictions with strategic anti-money laundering deficiencies. Despite the potential impact on financial aid the listing could have, Indonesia is still unable to pass effective rules on counter terrorist financing. The FATF recommended Indonesia address three specific points:

(1) Adequately criminalising terrorist financing (Special Recommendation II);
(2) Establishing and implementing adequate procedures to identify and freeze terrorist assets (Special Recommendation III); and
(3) Amending and implementing laws or other instruments to fully implement the 1999 International Convention for the Suppression of Financing of Terrorism (Special Recommendation I).

In March, Indonesian police officers from the notorious and elite Detachment 88 anti-terrorist squad. Officers shot and killed five suspected terrorists, who were funding planned attacks through armed robbery, targeting gold dealers and currency exchangers. This typology is well aired among the Indonesian banking compliance unit and the arrests put Indonesia’s CTF efforts on global news wires.

INCSR analysis

The US Department of State’s International Narcotic Control Strategy Report also highlighted endemic corruption as a chink in Indonesia’s AML/CTF armour.

Indonesia has a weak AML/CFT regime, according to the INCSR assessment, a cash-based economy, weak rule-of-law and ineffective law enforcement institutions, the presence of major indigenous terrorist groups combined reduce the impact of international standards and national law.

Non-drug related crimes generate the majority of money laundering activity: corruption, illegal logging, theft, bank fraud, credit card fraud, and maritime piracy, sale of counterfeit goods, gambling and prostitution.

Banks are already required to follow enhanced due diligence procedures for both foreign and domestic PEPs. Although the FATF recommendation on this was only made official in February this year, many financial institutions in Asia, perhaps influenced by other industry groups, had already adopted monitoring domestic PEPs as best practice.

KYC covered entities: Banks, finance companies, insurance companies and insurance brokerage companies, pension fund financial institutions, securities companies, investment managers, providers of money remittance, and foreign currency traders. NB High value goods dealers and lawyers are not covered by KYC rules.

Convictions and the law

There were four convictions for money laundering between January and October 2011.

In October 2010, the Government of Indonesia enacted a new AML law that partially complies with international standards. To meet international standards and ensure effective implementation and enforcement of the law, INCSR recommends staff in both the executive and judicial branches should receive more training on AML/CTF.

The PPATK – Indonesia’s Financial Intelligence Unit  – needs a significant increase in staff to meet its responsibilities under the law. In an effort to place some of the legal burden on industry and bank partners, PPATK plans to open three AML centers in different regions of Indonesia to serve as resource centers for organizations that must comply with the new regulations. There is hope that this will place some of the legal burden on AML/CTF on to practitioners and bank partners. How this will happen remains to be seen and will be a focus of discussion at the 4th Annual ACAMs Conference in early April.

Despite a reported high-level commitment to the action plan developed to address some of the persistent gaps in its AML/CFT legislation, the government has not met its projected timeframes. Essential draft CFT legislation will not be submitted to parliament until at least early 2012.

The October 2010 AML legislation only provides for the temporary suspension of terrorist assets linked to the UN list of designated terrorists and terrorist organizations and does not allow for an immediate and ongoing freeze.

Corruption, particularly within the police ranks, impedes effective investigations and prosecutions. Prosecutors and judges should be given additional training on tracing and documenting financial flows and presenting this evidence convincingly in court.

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