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Money Laundering Bulletin

Top three – FIU heads compare notes

Outside of Egmont Group meetings the paths of the directors of national Financial Intelligence Units (FIUs) cross only infrequently, even less in public. ACAMS’ 8th Annual European Anti-Money Laundering & Counter-Terrorism Financing Conference in Amsterdam therefore offered a valuable chance to discover how those in overall charge of handling reports in Luxembourg, the Netherlands and Estonia are thinking.

Jean-François Boulot, acting head of the Luxembourg FIU explained that it sits in the Financial Crime Division of the State Prosecutor’s Office: “There are five prosecutors who specialise in financial crime, five analysts, who work closely with the police, and a dedicated liaison officer with access to police intelligence.” Starting an investigation doesn’t depend on receipt of a suspicious transaction report (STR), as during the Arab Spring, in the first part of 2011, when the FIU was prompted to look at fund movements by other intelligence sources. Entities across the regulated sector were requested by circular to check if they held assets of suspect parties.

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