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SUMMARY OF SIGNIFICANT MEASURES FROM 2008 TO JAN 2014
� Internal Legal Measures� Technical Measures� Research and Training Measures� Executive Measures� Statistics, Facts and Figures� International Measures� Current Status of Designated Entities� Future Planning of IRIFIU, Opportunities
and Challenges
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SUMMARY OF SIGNIFICANT MEASURES FROM DEC 2008 TO JAN 2014
• Internal legal measures
1. An Independent Anti money laundering Act was adopted in 2008 by the parliament which Inter alia, constituted a High Council on Money Laundering comprising of several ministers
2. Executive By-Law of Anti Money Laundering Act was adopted in 2009 by the Cabinet that inter alia established Financial Intelligence Unit
3. Designation of an independent branch in public prosecutor’s Office in order to detect the crimes of Money Laundering. Also, by the notification of esteemed Head of Judiciary, main Justice administration of the provinces are obliged to designate a special branch for money laundering cases.
4. Preparation and ratification of combating financing of terrorism (CFT) bill in compliance with international standards in government and submitting it to the parliament. CFT approval by Parliament on 8th February 2012. It is still pending for final approval.
5. Providing the criminology of 20 international Predicate offences related to Money-Laundering international standards in the internal Laws and Regulations of the Islamic Republic of Iran.
6. Ratification and announcement of 13 AML Directives in Banks and Financial Institutions (May 2011), Stock Exchange, Customs (Oct 2011), Tax Organization, Insurance (November 2011), Notaries, DNFBPs, official Auditors, NPOs (June 2012).
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FINANCIAL INTELLIGENCE UNIT
� Domestic definition of IRIFIU: According to Article 4 of AML Act and Article 38 of Executive By-Law:
- To collect and obtain information on suspicious transactions
-To evaluate, scrutinize and analyze the information contained in
the reports and about suspicious transactions
-To supply analyzed information needed by judicial authorities,
executive officers and institutions responsible for combating money
laundering and terrorism financing in the country
-To provide necessary software and information systems
-To exchange information with international organizations and
institutions. 5
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Financial
Intelligence
Unit
IRIFIU
Banks and credit
institutions
Banks and credit
institutions
Insurance companies
and central insurance
corporation
Stock exchange
(capital market )
I.R.I Customs
Tax Affair organization
Municipalities
Notaries
Attorney
Accountants and
Audits
Official Experts
Guilds
Judiciary,
Public
Prosecutor
office
Law
Enforcement
Agencies
Supervisory
Organizations
Parliament
Council of
Ministers
International
Organization
other FIUs
Commercial Companies
organizations
Commercial Companies
and Non-profit
organizations
Non-Bank Financial
Institutions
According to Articles 5 and 6 of AML Act Designated Entities are as Follow
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• Technical Measures1. Preparation and announcement Roadmap and Action Plan of the year 2010-2014
2. Recognizing and preparing job description of all personssubject to the law suchas: Banking system, Insurance system, Stock Exchange, Customs, Taxorganization, Notaries, etc. in the 4 main parts of Regulation, Executive andInfrastructure, Training and Informational, Supervisoryand ControllingMeasures.
3. Preparation the list of indicators and instances of suspicious transactions in thesphere of bank, Insurance, stock exchange, customs, tax, etc.
4. Preparing the format and protocol of suspicious transaction reporting in the areasof all designated institutions to the IRIFIU.
5. Developing a web-based software in IRIFIU to collect suspicious transactionreports (STRs) from all banks and credit institutions, Insurance companies,Stock Exchange, Tax organization, Customs, etc.
Summary of Significant Measures from 2008 to Jan 2014
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• Technical Measures
7. Developing a web-based software to receive all enquiries and verify the identities for Designated Persons, Judicial Authorities, Law Enforcement Agencies and send responses.
8. Providing dedicated, secure channel between IRIFIU and Banks and other designated persons to exchange information.
9. Activating and updating the bilingual (En/Fa) website of the AML high council secretariat.(www.iranaml.com), (www.iranaml.ir)
Summary of Significant Measures up to Jan 2014
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• Research and Training Measures1. Establishment of Anti-Money Laundering Computer Based
Training (AML/CBT) centre in co-operation with UNODC in IRIFIU. So far, about 400 internal experts and 50 foreign experts (regional countries) passed this course, awarded by certificates.
Summary of Significant Measures up to Jan 2014
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• Research and Training Measures2. Holding 2 international workshops in cooperation with UNODC with the presence of more than 130 national representatives from Financial Institutions, Stock Exchange, Insurance Companies, Customs, Tax Affairs Organization, and other designated entities on 28-29 Nov. 2011, and 22-23 Oct. 2012.
Summary of Significant Measures up to Jan 2014
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• Research and Training Measures3. Holding 6 national and international workshops on AML/CFT trends and methods in the AML High Council secretariat with the presence of Judicial Authorities, Law enforcement agencies (Interpol, Investigation Police, Drug Control Police) Central Bank, other High Council member delegates and representatives of all designated entities.
Summary of Significant Measures up to Jan 2014
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STR Analysis Procedure in IRIFIU
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STR Analysis Procedure in IRIFIU
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STR Analysis Procedure in IRIFIU
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Percentage of
Suspicious CasesTotal Percent
Under
Investigation
STRs in
Watch list
and Non-
STRs
STRs forward to
Law
Enforcement
Agencies
Total
No.
Bank/Financial
Institutions
18.75%1.45%013316Sarmayeh Bank38.74%20.09%1212486222Saderat Bank55.88%9.23%93657102Melli Bank13.79%2.62%025429Ayandeh Bank50.00%0.72%0448Central Bank25.00%2.17%216624Parsian Bank
38.78%4.43%0301949Export
development
Bank5.88%3.08%527234Maskan Bank
20.00%0.90%08210Eghtesad-e NovinBank
11.63%3.89%1028543Tejarat Bank8.22%6.61%760673Sina Bank
40.00%1.36%18615Refah Bank16.67%0.54%0516Saman Bank6.25%1.45%114116Sepah Bank7.69%2.35%717226Keshavarzi Bank
18.18%1.99%513422Mellat bank
6.90%2.62%225229Qarzol-HasanehMehr Iran Bank
9.52%3.80%430442Securities and
Exchange
Organization
The STRs Statistics Until Jan 2014
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Percentage of
Suspicious
Cases
Total
Percent
Under
Investigation
STRs in Watch list
and Non-STRs
STRs forward to
Law Enforcement
Agencies
Total No.Bank/Financial
Institutions
19.05%1.90%413421Dey Bank0.00%0.18%1102Shahr Bank8.33%2.17%121224Pasargad Bank0.00%0.45%0505Hekmat Bank
22.73%1.99%017522Bank of Industry andMine
8.82%3.08%130334Customs0.00%0.00%0000Interpol4.80%11.31%121076125Ansar0.00%3.98%044044Ghavamin0.00%0.72%1708Post Bank
50.00%0.36%0224Tax Affairs Organization
33.33%0.27%1113Iran-Venezuela Bank16.67%0.54%3216Iran Zamin Bank0.00%2.08%1211023Tose’e Ta’avon Bank0.00%0.09%0101IACPA0.00%0.27%0303Natural Persons
Reports40.00%0.90%60410Other Designated
Entities0.00%0.18%1102Tourism Bank0.00%0.09%1001Tosse-eh Credit
Institute
0.00%0.09%0101Karafarin Bank21.90%100.00%1137502421105Total No.
The STRs Statistics Until Jan 2014
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Statistics for Percentage of Received STRs by IRIFIU Until Jan 2014
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Name of Bank The Percentage of
Responses to Inquiries
Melli 92
Mellat 98
Saderat 96
Tejarat 100
Sepah 95
Maskan 89
Keshavarzi 88
Export development 100
Tose’e Ta’avon 100
Industry and Mine 100
Qarzol-Hasaneh Mehr Iran 100
Refah 100
Statistics for Number of inquiries from Designated Entities
Until Jan 2014
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Name of Bank The Percentage of
Responses to Inquiries
Shahr 100
Ayandeh 100
Parsian 100
Eghtesad-e Novin 100
Saman 97
Sarmayeh 100
Pasargad 100
Dey 100
Tosse-eh Credit Institute 18
Post Bank 100
Sina 100
Statistics for Number of inquiries from Designated Entities
Until Jan 2014
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Name of Bank The Percentage of
Responses to Inquiries
Ansar 100
Karafarin 100
Ghavamin 100
Iran Zamin 100
Hekamat Iranian 100
Tourism 69
Investigation Police 33
Iran-Venezuela 100
Kowsar Credit Institution 100
Statistics for Number of inquiries from Designated Entities
Until Jan 2014
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• International measures
� International Monetary Fund (IMF)
1. Precise survey of the IMF sent reports (in the track of visiting Iranin October 2008)
2. Active participation in two workshops held by the Fund in Austriain the years of 2008 and 2009.
3. Holding technical meetings with the IMF delegation on theCFTBill and measures taken by I.R. Iran on AML in June 2010
4. Set an internal agreement to have a mutual assistance programbetween authorities
5. Set an internal agreement to have the assessment of I.R of IranAML/CFT regime by Fund in 2014
Summary of Significant Measures from Dec 2009 to Jan 2014
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• International measures� United Nation Office On Drugs and Crimes(UNODC)10. Having constructive and effective relationships with its
Tehran Representative and Headquarter fromOctober 2008in the sphere of technical assistance (Sp. Establishment ofAML/CBT center in September 2009).
11. Active participation in 12 local conferences and workshopsheld by this office in Iran in the period of 2008-2012.
12. Participating in the study and research missions abroad heldby the office to Italy, Austria, Thailand, Nether land, etc.
13. Active co-operation in the ongoing projects (Sp. FIUto FIUProgram2011-2014) of the office in AML/CFT sphere.
Summary of Significant Measures from Dec 2009 to Jan 2014
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• International measures� United Nation Office On Drugs and Crimes(UNODC)14. Making Financial Contribution to the current program (subprogram 2) in
the field of AML/CFT
15. H.E Mr.Yury Fedotov-Executive Director of UNODC expressed
his satisfaction over Iran’s Anti-Money Laundering effective
measures during a meeting with the esteemed Minister of
Economic and Finance Affairs in July 2011.
Summary of Significant Measures from Dec 2009 to Jan 2014
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• International Measures� EGMONT GROUP16. Evaluation of joining procedure to this group and preparation
of the required documents and papers (Laws, Regulations, measures, etc).
17. Sending a specialist board to Armenia as the 1st sponsor of the Islamic Republic of Iran Financial Intelligent Unit (IRIFIU) in joining to EGMONT GROUP and commencing the process with special timetable for the membership in this group as well as signature of MOU (May 2010).
18. Counseling With Ukraine FIU as the 2nd sponsor of Iran for MOU signature and implementation of the second phase of joint procedure to this group (May 2013).
Summary of Significant Measures from Dec 2009 to Jan 2014
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• International Measures� Bilateral and multi-lateral interactions with other countries19. Holding the official inauguration ceremony of the High Council Secretariat
and IRIFIU laundering on the 7th of February 2010 with the presence of theambassadors and delegates of 34 foreign countries and other local authorities.
20. Holding the common meeting of the esteemed minister of Economic Affairsand Finance with the delegates and ambassadors of over 30 MDG countries inTehran with the subject of the description of our country AML/CFTachievements on the 1st of June 2010.
21. Signature of MOU between IRIFIU and Armenia(May 2010), Brazil(January2011), Slovenia (June 2011), Ecuador (Aug 2011), Tajikistan (May 2012)FIUs. The Latest MOU was signed this week with Pakistan. Iran is partytoUN convention against illicit traffic in Narcotic drugs and pyschotropicsubstances , UNCAC and soon to be joining UNTOC.
22. Final stages of agreement to sign MOU with Russia, Thailand, Kazakhstan,Turkmenistan FIUs.
Summary of Significant Measures from Dec 2009 to Jan 2014
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• International Measures� Bilateral and multi-lateral interactions with other countries23. Holding triangular coordination meetings among the Islamic
Republic of Iran, Afghanistan and Pakistan FIUs (5 times), tonegotiate and sign MOUs on AML/CFT sphere.
24. Holding common meetings with the delegates of the CIScountries including: Turkmenistan, Uzbekistan, Azerbaijanand Kyrgyzstan to discuss about cooperation on AML/CFT(5 times: July 2010, January 2011, July2011, February 2012,Apr 2013).
25. Negotiation and sending proposed MOUto the competentauthorities of Italy, Austria, Belgium, Turkey, Malaysia,Indonesia, India, Bangladesh, Venezuela, China, etc.
Summary of Significant Measures from Dec 2009 to Jan 2014
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• In cooperation with Renovation and AdministrativeDevelopment Center a secure MPLS network establishedand usernames and passwords of the system delivered toall Banks, Insurances, Stock Exchange, Tax AffairsOrganization, Customs, Iranian Association of CertifiedPublic Accountant (IACPA), Audit Organization,Organization of Lands and Deeds Registration and othersubject to law agencies established. Moreover, all duties ofdesignated entities were provided in a web-based system inaccordance with the Action Plan and Road Map.
• To control and monitor all of the designated entities inimplementation of AML laws and regulations
• Use of MS Project software through EPM (EnterpriseProject Management)
Global Program Against Money Laundering of Iran (GPMLI)
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Following Institutions and Organizations are
connected online to this system for exchange of
information:
� Central Bank and about 35 private and public Banks,
Financial and Credit Institutions,
� Securities and Exchange Organization,
� Customs,
� Tax Affairs Organization,
� Iranian Association of Certified Public Accountant
(IACPA) and Audit Organization,
� More than 20 private and public insurance companies.
Active Users
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ACTIVE USERS
The Project for Following Institutions and
Organizations is in planning stage:
� National Organization for Notarization of Deeds and
properties,
� Non-Bank Financial Institutions (Credit Cooperatives,
Interest-free Loan Funds, Leasing Companies, and
Foreign Exchange Bureaus),
� Guilds.
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Project Sample
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PROJECT PROPERTIES
Project has 4 main parts within framework of Road Map approved by AML High Council:
� Directives and Circulars,
� Infrastructure and Executive Measures
� Training and Information Measures,
� Control and Supervisory Measures.
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PROJECT DASHBOARD SAMPLE
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PROJECT DASHBOARD SAMPLE
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Current Status ofBanks in Enterprise Project Management
System
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Statistics for Progress in Percentage of AML Achievements by Banks
by Jan 2014
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Status of Organizations:
Stock Exchange, Tax Affairs Organization, Customs, Iranian Association of
Certified Public Accountant (IACPA) and Audit
Organization
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Statistics for Rate of Progress in Percentage of AML Achievements
by Jan 2014
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Statistics for Rate of Progress in Percentage of AML Achievements by Insurance Companies
by Jan 2014
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FUTURE PROSPECT
• Preparation and announcement Roadmap and Action Plan of the year 2014-2017
• Developing related activities in the field of AML/CFT in all designatedentities such as municipalities, attorney at law, and etc.
• Preparing a suitable mechanism for implementing CFT Bill.
• Preparing and executive of infrastructure for implementing AML Act incommercial companies and non-profit organizations.
• pursuing to obtain suspicious transaction reports from designated
persons, through prepared software and increasing the quality of
those reports.
• Developing information exchange and cooperation with Judicial Authoritiesand law enforcement agencies
• improving international cooperation for AML/CFT through varietyof bilateral or multilateral MOUs with other FIUs and also with
related international organizations.
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