Accounting Principles 13th Edition Answers Pdf
Fortun Bawa
Commission communication to the Council, the European Parliament and the European Economic and Social Committee - The Prevention of and Fight against Terrorist Financing through enhanced national level coordination and greater transparency of the non-profit sector. /* COM/2005/0620 final */
Analysis of national coordination structures reveals a number of horizontal best practices to strengthen information sharing at national level among all Relevant Actors and from which the following can be deduced:
1.1. To help address policy coordination, consideration may be given to establishing a national framework comprising all Relevant Actors. This will help build consensus around a national CFT strategy. It should promote confidence building, understanding and trust between agencies. Core tasks should include production of a Joint Counter Terrorism Action Plan, joint CFT risk and threat analyses and other joint CFT research[11]. Structures should be put in place to ensure that Relevant Actors are consulted, contribute to and have to sign off joint analysis of intelligence on methods used by terrorists to finance their activities. The benefits of including appropriate private sector representatives in this work should also be considered.
1.3. Operational coordination could be further enhanced by national networks, connecting in each Member State the respective FIU with, on the one hand, reporting bodies and, on the other hand the Relevant Actors. This would create an automated yet secure electronic environment for the receipt, processing and dissemination of financial intelligence. It would enable the direct transfer of information from financial institutions into special databases in the FIU, support the computer-assisted production of financial intelligence within the FIU and allow for the automated exchange of information between FIU and Relevant Actors. This work is currently being assessed in the FIU NET project.
1.4. Minimum standards for collection, analysis and dissemination of intelligence. This would facilitate intelligence generation and sharing and promote an intelligence driven and risk based approach. Standards should emphasise the need to derive meaning and value from collected information and a common commitment to disseminate that information rapidly to authorised persons in other Relevant Actors.
1.5. Developing minimum standards for handling information such as confidentiality levels, security clearances, document handling codes would facilitate and expand rapid and effective information exchange among Relevant Actors.
1.6. Financial intelligence should support and supplement overall counter terrorist activity. Integration within general counter terrorist activity of input from a body responsible for CFT coordination would help ensure that financial intelligence is an integral part of counter terrorist activity. This should also produce value in bridging the gap that may exist between specialised CFT police, Counter Terrorist police and intelligence services.
2.1. A number of Member States said they had formalised terrorist financing information exchange structures between the Finance, Interior and Justice Ministries and described how this process had given a new impetus to the fight against terrorist financing by bringing together the intelligence services, specialised police and FIU.
2.3. Member States should promote awareness among law enforcement of the role the FIU can play in assisting their fight against terrorism financing and other criminality. The use of Memoranda of Understanding between the FIU and other agencies may help to provide the framework for efficient access to financial information.
2.4. CFT experts within the FIU should have appropriate security clearance to allow them to receive, transmit and jointly analyse financial intelligence with intelligence services or other Relevant Actors handling security coded data. The need for appropriate security clearances within other Relevant Actors should also be considered so that classified information can be shared and jointly analysed where necessary.
2.5. Coordination in the fight against terrorist financing is likely to be facilitated where the FIU includes a dedicated CFT unit facilitating closer coordination with CFT and CT experts in other Relevant Actors. Focused CFT experts within the FIU also ensure a greater awareness of CFT typologies and so facilitate identification and prioritisation of high risk cases. These expert units should ensure a multi-agency approach through structured coordination with police, prosecutors and intelligence services. Such units should be encouraged to compare approaches with their counterparts in other Member States.
2.6. To enhance mutual understanding, particularly where no formal structures exist, Member States should encourage secondment of investigative magistrates, prosecutors, financial investigators, analysts and others to the FIU as well as to and from other Relevant Actors.
2.8. Use of key words, key names and other identifiers to encourage immediate identification of terrorist related suspicious transaction reports. Appropriate forms of co-operation should be established between FIUs and operational specialised services, including the exchange of information on suspicious transactions for intelligence purposes and possible disruption of terrorist acts.
2.9. The complexity of CFT work is such that know how and expertise must frequently be combined, for example, by allowing experts with complementary skills to be seconded on an ad hoc basis for a given project, investigation or prosecution. One Member State illustrated this citing structures created which allow and facilitate a prosecutor with expertise in financial crime to act jointly with a prosecutor with an anti-terrorism background in connection with CFT cases.
2.10. As well as ensuring that employees of reporting bodies are informed of typologies and threats, Member States in conjunction with financial and other institutions should ensure that users of financial services are informed about how they can assist both public and private sector efforts to combat the financing of terrorism and other financial crime.
In many cases it is not so much the financial information per se held by banks and others which is of vital importance to law enforcement efforts, but rather the intelligence which that information can provide. For this reason it is essential to ensure good coordination between Relevant Actors and financial institutions (and other money laundering reporting bodies) so that necessary information can be obtained easily and rapidly and with appropriate guidance from Relevant Actors.[12] Public sector intelligence can be enhanced by financial institution input. For example, in some Member States important lead information has been obtained where sensitive information, such as data on forged identity documents, has been shared with financial institutions to identify and locate suspects.
3.3. Good practice indicates that suspicious activity should be reported to the FIU even where it does not relate to a transaction , such as where strong enough suspicion surrounds a financial institution rejection of an application to open an account for example where the person fails to provide adequate identifying information.
3.4. Encourage effective operation of liaison committees between one or more Relevant Actors and representatives of financial and credit institutions and other reporting bodies. Regular meetings of liaison committees, chaired by the national CFT coordinating body and/or the FIU, are an essential means of mobilising and providing outreach to the private sector, informing it of developing typologies in terrorist financing and updating risk indicators. In addition to structured liaison committees, dedicated CFT contact points should exist in financial institutions to facilitate rapid contact by FIU and other Relevant Actors. Regular feedback to reporting bodies will help ensure high quality reports to FIUs.
3.6. Secondment even for a short period, of financial police / FIU staff / intelligence personnel to private sector data holders should be encouraged. This enhances public sector understanding of how private sector data are managed and the ease or difficulty involved in retrieving certain types of information.
Taking account of the potential vulnerabilities of the non-profit sector to terrorist financing and other criminal abuse, the Commission addresses a Recommendation to Member States and a Framework for a Code of Conduct for NPOs acting in the European Union.
The Commission has extensively consulted with Member States and the non-profit sector during the preparation of the Recommendation and Framework for a Code of Conduct including an eight week internet-based public consultation.
In particular, during the course of first half of 2006, the Commission will set up an informal contact group and organise a conference with representatives of the non-profit sector and relevant authorities to consider possible ways of further implementation of principles laid down in the Recommendation and Framework for a Code of Conduct.
It should be further discussed with relevant stakeholders how partnership between NPOs and state authorities could be developed to find an appropriate balance between statutory and self-regulation for the non-profit sector .
ANNEX Recommendation for Member States and a Framework for a Code of Conduct for NPOs to Enhance Transparency and Accountability in the Non-profit Sector to Prevent Terrorist Financing and other Types of Criminal Abuse
The non-profit sector carries out vital humanitarian and other much needed public work, where citizens benefit from their indispensable services in fundamental areas of life. NPOs are essential parts of democratic societies that often fulfil crucial tasks that other types of organisations or public bodies cannot achieve.
Higher and/or more systematic standards of transparency and accountability applied by NPOs will help to strengthen the non-profit sector against criminal abuse. The present document aims to find an approach that minimises this risk of abuse without over-burdening the sector. The basic principles set out in the Communication should in no way be interpreted so as to restrict the freedom of association. Particular attention should be paid to data protection rules. Moreover, implementation of the Recommendation to Member States and the Framework for a Code of Conduct should not jeopardise the efficient provision of emergency relief and other non-profit activity where needed. Care must be taken to ensure that nothing is done that could undermine the work or reputation of the vastest majority of NPOs legitimately operating at national, EU and international levels.
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