The Financial Action Task Force (FATF) conducted a mutual evaluation of Greece's Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) regime against the FATF's 40+9 recommendations and special recommendations. The FATF published its findings in a 2007 report, in which it concludes that Greece is compliant with only 2 FATF recommendations and special recommendations; largely compliant with 10; partially compliant with 23; non compliant with 13; and one recommendation is not applicable to Greece. Overall, the mutual evaluation notes that Greece's AML/CFT framework is inadequate to meet FATF standards. More specifically the FATF report mentions the lack of adequate legal systems to prevent money laundering and terrorist financing, and the lack of adequate preventive measures and regulatory oversight. The FATF report notes that Greece's AML/CFT system is undermined by the money laundering offence only including predicate offences where the offence generated property worth at least EUR 15,000. Furthermore, the scope of the terrorist financing offence is prohibitively narrow as it does not criminalize collecting or providing funds or material support to terrorist individuals or for specific terrorist acts. Regarding customer due diligence (CDD) measures, the mutual evaluation states that the requirement to conduct CDD does not extend to all of the financial sector (i.e. insurance brokers and agents) and that the basic obligations (i.e. when to conduct CDD or measures to identify legal persons) are not consistently set out in Greek laws or regulations. Most recently, according to a July 2008 press release by the Greek Ministry of Economy and Finance, a bill was tabled in the Greek Parliament on July 17, 2008 requiring the transposition of the European Union’s Third Directive and the FATF’s recommendations on AML/CFT into Greek law.

General Overview

The Financial Action Task Force (FATF) conducted a mutual evaluation of Greece's Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) regime against the FATF's 40+9 recommendations and special recommendations and published its findings in a 2007 report. The report concluded that “Greece’s legal requirements in place to combat money laundering and terrorist financing are generally inadequate to meet the FATF standards and there are some serious concerns about the effectiveness of the AML/CFT system in place” (p. 6). The report also notes that Greece is compliant with only 2 FATF recommendations and special recommendations; largely compliant with 10; partially compliant with 23; non compliant with 13; and one recommendation is not applicable to Greece. However, according to a July 2008 press release by the Greek Ministry of Economy and Finance a bill was tabled in the Greek Parliament on July 17, 2008 “aimed at upgrading the mechanisms used in Greece to prevent and suppress money laundering and terrorist financing. The bill, which was drafted by a special legislative committee, transposes into Greek law not only the Third Community Directive 2005/60/EC and its implementing Directive 2006/70/EC but also the Recommendations of the Financial Action Task Force (FATF), the recognized international body responsible for laying down international criteria and standards for combating the above offences.”

Money laundering is criminalized pursuant to Law No. 2331 of 1995 (henceforth the AML Law) on prevention and combating of the legalization of income from criminal activity as amended by Law No. 3424 of 2005. For natural persons, money laundering is punishable by 5-10 years of imprisonment, and for legal persons, an administrative fine of up to about EUR 3 million is imposed. Terrorist financing is criminalized pursuant to Article 40 of Law No. 3251 of 2004, which inserted Article 187A into the Greek Penal Code and covers several terrorism-related offences designated collectively as “Terrorist Acts.” Under Law No. 3251, the applicable criminal penalty is imprisonment for up to 10 years. According to the 2008 U.S. DoS report, the Bank of Greece (BoG) has circulated to all financial institutions under its supervision the list of individuals and entities on the United Nations Security Council Resolution (UNSCR) 1267 Sanctions Committee’s consolidated list of those suspected to be linked to Osama Bin Laden, Al-Qaida and the Taliban.

The FATF report points out that Greek law allows for the seizure of assets upon conviction for a money laundering offense with a jail term of three years or more. Specifically, the 2008 U.S. DoS report observes that the AML Law "empower[s] supervisory authorities to block transactions when money laundering is suspected and authorizes the financial intelligence unit (FIU) director to temporarily freeze assets without a court order." However, the FATF mutual evaluation cites several weaknesses in Greece's confiscation, freezing and seizing system, namely: (1) indirect proceeds cannot be confiscated; (2) seizures do not extend to all property that is the proceeds of crime; and (3) courts cannot void or prevent transactions from the time the crime has been committed.

Created in 1995 and chaired by a senior retired judge, the Competent Committee (CC) functions as Greece's FIU. Established under Law No. 2331 of 1995, the CC's primary mission is to collect, analyze and disseminate all suspicious transaction reports (STRs) submitted by entities subject to the AML Law to the CC's investigative arm, the Special Control Service (YPEE), for further investigation. According to the 2008 U.S. DoS report, Law No. 3424 of 2005 (an amendment to the AML Law) "makes the CC a statutorily independent authority with access to public and private files and removes tax confidentiality restrictions." The U.S. DoS report states that the CC receives approximately 1,000 STRs per year. Nevertheless, the FATF mutual evaluation highlights several weaknesses in the CC's mandate, namely: (1) insufficient staff and resources to adequately perform its functions; (2) lack of sufficient and timely access to all information required to adequately perform its functions; and (3) a considerable lack of effectiveness due to the use of a paper-based STR system and the paucity of IT infrastructure, which undermines the overall effectiveness of the AML/CFT system.

The FATF report highlights some key deficiencies with Greece's CDD regime. For example: (1) the requirement to conduct CDD does not extend to all sectors of the financial services sector (i.e. insurance brokers and agents); (2) the basic obligations (i.e. when to conduct CDD or measures to identify legal persons) are not consistently set out in Greek laws or regulations; and (3) the responsibility to conduct CDD is not extended to all scenarios required by FATF Recommendations, such as situations where there is a suspicion of money laundering or terrorist financing and those where doubts arise surrounding previously obtained CDD information. Pertaining to STRs, the FATF report points out that, in addition to criminalizing money laundering, the AML Law requires reporting entities (both banks and non-bank financial institutions) to submit STRs to the CC. Furthermore, the AML Law requires each reporting entity to employ a compliance officer to whom all other officers must file STRs. The evaluation noted the following as deficiencies: (1) insurance agents and brokers are not covered by the requirement to file STRs; (2) not all predicate offences required in Recommendation 1 are included in scope; and (3) not all the required aspects of terrorist financing are included in the scope of the STR filing requirement.

According to the mutual evaluation, the AML Law has imposed AML/CFT obligations on certain categories of Designated non-Financial Business and Professions (DNFBPs) since 1995, including real estate agents, casinos, chartered accountants and auction houses, whenever the transaction value exceeds EUR 1,500. However, the evaluation highlights some key shortcomings in Greece's DNFBP system. For example, the main deficiencies noted in the AML/CFT preventive measures applicable to financial institutions apply also to DNFBPs as stipulated by the AML Law. Other deficiencies include: (1) Trust and Company Service Providers (TCSPs) are not covered by the AML Law; (2) the AML Law covers internet casinos but there is no action taken in practice; and (3) despite DNFBPs being technically subject to various provisions of the AML Law, practical application is extremely limited.

According to the U.S. DoS report, Greece is a party to the 1988 UN Drug Convention (the Vienna Convention) and the UN International Convention for the Suppression of the Financing of Terrorism. Greece is signatory to the UN Convention against Transnational Organized Crime (the Palermo Convention) and to the UN Convention against Corruption, but has not yet ratified them. Also, the CC belongs to the Egmont Group. The FATF report notes that, as of the release of the report in June 2007, Greece's implementation of the Palermo Convention is undermined by the money laundering offence being too limited and that self-laundering is not properly criminalized in Greece. Pertaining to Greece's implementation of the Terrorist Financing Convention, the FATF report states that the penalties are not dissuasive.

The Principles

1. Legal Systems and Related Institutional Measures

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The 2007 FATF report concluded that “Greece’s legal requirements in place to combat money laundering and terrorist financing are generally inadequate to meet the FATF standards and there are some serious concerns about the effectiveness of the AML/CFT system in place” (p. 6). The report finds Greece partially compliant with Recommendation (R) 1 regarding the money laundering offence and partially compliant with R 2 on its mental element and corporate liability. Money laundering is criminalized pursuant to Law No. 2331 of 1995 on prevention and combating of the legalization of income from criminal activity as amended by Law No. 3424 of 2005. For natural persons, money laundering is punishable by 5-10 years of imprisonment, and for legal persons, an administrative fine of up to about EUR 3 million. However, regarding deficiencies in Greece's money laundering legal framework, the 2007 FATF report notes that: (1) the money laundering predicate offences are limited by the threshold of EUR 15,000; (2) the money laundering offence requires the prosecution to prove all elements of the predicate offence, which makes prosecution much more difficult; and (3) self-laundering is not obviously criminalized.

Greece is partially compliant with Special Recommendation (SR) II on the criminalization of terrorist financing as noted in the 2007 FATF report. Terrorist financing is criminalized pursuant to Article 40 of Law No. 3251 of 2004, which inserted Article 187A into the Greek Penal Code and covers several terrorism-related offences designated collectively as “Terrorist Acts.” However, regarding deficiencies in Greece's terrorism financing legal framework, the 2007 FATF report notes that: (1) the scope of the offence is prohibitively narrow as it does not criminalize collecting or providing funds or material support to terrorist individuals or for specific terrorist acts; (2) criminal liability does not apply to legal persons and there is no fundamental principle of law prohibiting it; and (3) there have been no terrorist financing cases and as such it is difficult to assess whether the offence is being effectively implemented. The FATF report further recommends that terrorist financing "be a stand alone offence for which prosecution is available, regardless of whether the group actually carries out or attempts a specific terrorist attack" (p. p. 180-181).

Concerning confiscation, freezing and seizing of proceeds of crime (R 3), the FATF's mutual evaluation rates Greece as partially compliant. The FATF report points out that Greek law allows for the seizure of assets upon conviction for a money laundering offense with a jail term of three years or more. Specifically, the 2008 U.S. DoS report observes that the AML Law "empower[s] supervisory authorities to block transactions when money laundering is suspected and authorizes the financial intelligence unit director to temporarily freeze assets without a court order." However, the FATF mutual evaluation cites several weaknesses in Greece's confiscation, freezing and seizing system, namely: (1) indirect proceeds cannot be confiscated; (2) seizures do not extend to all property that is the proceeds of crime; and (3) courts cannot void or prevent transactions from the time the crime has been committed.

With regards to SR III relating to the freezing of terrorist financing-related assets, the FATF mutual evaluation rates Greece as partially complaint. The FATF notes as a particular weakness in Greece's terrorism financing confiscation and seizure regime that there must be an active investigation before Greek law enforcement authorities can seize assets, thereby undermining the ability to promptly freeze terrorist assets. According to the 2008 U.S. DoS report, the BoG has circulated to all financial institutions under its supervision the list of individuals and entities on the United Nations Security Council Resolution (UNSCR) 1267 Sanctions Committee’s consolidated list of those suspected to be linked to Osama Bin Laden, Al-Qaida, and the Taliban. However, the U.S. DoS report also notes that, as at the release of the report in March 2008, Greek authorities have yet to find "any accounts belonging to anyone on the circulated lists." The 2007 FATF mutual evaluation attributes the "partially compliant" rating for SR III to some critical deficiencies namely: (1) the definition of "funds" in the EC Regulations does not fully cover the terms required by SR III; (2) Greece has a limited ability to freeze funds in compliance with S/RES/1373 (2001) of designated terrorists beyond the EU listing system; and (3) Greece lacks the adequate means through which a person or entity whose funds have been frozen can dispute such rulings before a court.

In terms of the financial intelligence unit (FIU) and its functions, the 2007 FATF report classifies Greece as non-compliant with R 26; non-compliant with R 30 about resources, integrity and training; and non-compliant with R 32 on statistics keeping. Created in 1995 and chaired by a senior retired judge, the Competent Committee functions as Greece's FIU. Established under Law No. 2331 of 1995, the CC's primary mission is to collect, analyze and disseminate all STRs submitted by entities subject to the AML Law to the CC's investigative arm, the YPEE, for further investigation. According to the 2008 U.S. DoS report, Law No. 3424 of 2005 "makes the CC a statutorily independent authority with access to public and private files and removes tax confidentiality restrictions." The U.S. DoS report states that the CC receives approximately 1,000 STR's per year. Nevertheless, the FATF mutual evaluation highlights several weaknesses in the CC's mandate such as: (1) insufficient staff and resources to adequately perform its functions; (2) lack of sufficient and timely access to all information required to adequately perform its functions; and (3) a considerable lack of effectiveness due to the use of a paper-based STR system and the paucity of IT infrastructure, which undermines the overall effectiveness of the AML/CFT system. The 2008 U.S. DoS report observes that the CC "recently established a database to track STR submissions." However, the report concludes that the CC still lacks "elements of a technology-savvy modern organization."

The FATF's mutual evaluation observes that Greece is largely compliant with R 27 on law enforcement authorities; compliant with R 28 on the powers of competent authorities; non-compliant on resources, integrity and training (R 30); and non-complaint on statistics (R 32). The FATF report commends Greece for the overall soundness of its AML/CFT law enforcement and prosecution regime, particularly noting that Greece's three main AML/CFT law enforcement agencies, the Hellenic Police, the Special Control Service within the MEF and the Hellenic Customs Service are sufficiently staffed and equipped with the legal powers to prosecute all forms of money laundering and terrorism crimes. Furthermore, the 2008 U.S. DoS report notes that the CC prepares money laundering cases on behalf of the Public Prosecutor's Office. However, the FATF mutual evaluation observes that "the system put in place by the AML Law does not prevent parallel investigations (and then duplication of efforts) on ML [money laundering] or FT [financing of terrorism] cases" and "the resources of the prosecution service are insufficient for it to effectively perform its functions, taking into account the structure of the criminal justice system and the appeal procedures" (p. 178).

2. Preventive Measures - Financial Institutions

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The 2007 FATF report states that “there are deficiencies in AML/CFT supervision in the banking area and, to a more severe extent, in the securities sector. Measures are non-existent in the insurance sector” (p. 6). CDD requirements in Greece are lacking and not in line with the international standards per the report. Similarly, the report states that “given the size and increasing sophistication of criminal activity in Greece, the total number of suspicious transactions reports appears low, with virtually none from outside the banking sector” (p. 6). However, the report notes that recently the BoG has taken measures to introduce more comprehensive requirements for the financial institutions under its supervision.

As reported in the 2007 FATF report Greece is partially compliant with R 5 relating to customer due diligence and non-compliant on R 6 concerning politically exposed persons. On correspondent banking (R 7), Greece is largely compliant, and on new technologies and non face-to-face business (R 8), Greece is rated as partially compliant. The FATF report highlights some key deficiencies with Greece's CDD regime. For example: (1) the requirement to conduct CDD does not extend to all services of the financial sector (i.e. insurance brokers and agents); (2) the basic obligations (i.e. when to conduct CDD or measures to identify legal persons) are not consistently set out in Greek laws or regulations; and (3) the responsibility to conduct CDD is not extended to all scenarios required by FATF Recommendations, such as situations where there is a suspicion of money laundering or terrorist financing and those where doubts arise surrounding previously obtained CDD information. In its 2008 report, the U.S. DoS recommends that Greek authorities "amend the existing legislative and regulatory framework to ensure that appropriate CDD requirements are implemented."

For R 6 regarding politically exposed persons (PEP), the FATF report noted major shortcomings, namely the fact that "the requirement to identify and conduct CDD on PEPs does not extend to the securities and insurance sectors" and that the "BoG Governor's Act applies the requirements relating only to PEPs from countries outside the EU" (p. 174). On new technologies and non face-to-face business (R 8), the FATF report particularly noted the absence in Greek law or regulations of specific requirements for the securities or insurance sectors. On July 17 2008, the Greek government tabled a bill in Parliament to upgrade the mechanisms used in Greece to prevent and suppress money laundering and terrorist financing. Regarding PEPs, the bill would transpose into Greek law the Third European Union Directive 2005/60/EC. The bill would also implement Directive 2006/70/EC, which applies measures for Directive 2005/60/EC of the European Parliament and of the Council as regards the definition of ‘politically exposed person’ and the technical criteria for simplified customer due diligence procedures.

The FATF's mutual evaluation rates Greece largely compliant with R 10 on record keeping, and partially compliant with SR VII on wire transfer rules. The primary shortcoming cited for the partial compliance rating for Greece on SR VII was that the EU regulation for wire transfers within the EU does not comply with FATF requirements under SR.VII. Furthermore, "there are currently no sanctions for non-compliance with the EU regulation, and the sanctions regime generally is not effective or dissuasive" (p. 182).

The FATF mutual evaluation rated Greece partially compliant with R 13 relating to suspicious transaction reporting and compliant with R 14 about protection and no tipping-off. Pertaining to STRs (R 13), the FATF report points out that, in addition to criminalizing money laundering, the AML Law requires reporting entities (both banks and non-bank financial institutions) to submit STRs to the CC. Furthermore, the AML Law requires each reporting entity to employ a compliance officer to whom all other officers must file STRs. With regards to R 13, the evaluation noted the following as deficiencies: (1) insurance agents and brokers are not covered by the requirement to file STRs; (2) not all predicate offences required in Recommendation 1 are included in scope; and (3) not all the required aspects of terrorist financing are included in the scope of the STR filing requirement. The U.S. DoS report states that the CC receives approximately 1,000 STR's per year.

On R 19 regarding other forms of reporting, the mutual evaluation rates Greece as non-compliant, and Greece is given a non-compliant rating with R 25 on guidelines and feedback. The evaluation also rates Greece as partially compliant with SR IV relating to suspicious transactions reporting linked with terrorism. As with R 13, the FATF report attributed the same reasons to its less than stellar assessment of Greece against SR IV.

The 2007 FATF mutual evaluation finds Greece partially compliant with R 15 relating to internal controls, compliance and audit. The FATF mutual evaluation notes that, while the AML Law requires financial institutions supervised by the BoG to establish internal controls, the report also notes that these internal control requirements are not fully AML/CFT-oriented. In addition, for the insurance and securities sectors, the FATF report states that the existing internal control requirements are either very general or non-existent. On R 22 addressing foreign branches and subsidiaries, Greece is rated as partially compliant. This low rating was due to two main shortcomings, namely: (1) the AML Law provisions are insufficient to address all the elements of Recommendation 22; and (2) for BoG-supervised financial institutions, Greek laws do not explicitly require branches and subsidiaries of Greek institutions located in third countries to apply the higher standard permitted by local laws.

According to the 2007 FATF report, Greece is partially compliant with R 17 regarding sanctions and R 23 relating to regulation, supervision and monitoring. On R 29 about supervisors, Greece is also rated partially compliant. Regarding R 17, the FATF report notes that for BoG-supervised financial institutions "the range of sanctions imposed is not sufficiently broad and is not proportionate to the severity of a situation" (p. 176). Furthermore, for financial institutions supervised by the HCMC, "due to the very low volume of compliance monitoring carried out by the HCMC, the effectiveness of the sanctions regimes cannot be measured" (p. 176). Pertaining to regulation, supervision and monitoring (R 23), the FATF report cites as primary limitations, the absence of a licensing requirement or AML/CFT supervision for insurance agents or companies in Greece and the lack of resources and qualified personnel, which undermine the quality of supervisory programs and procedures. The FATF report highlights several key deficiencies with Greece's supervisors' regime (R 29). For example: (1) while equipped with sufficient supervision powers, the BoG has not employed these powers in an effective way; (2) the HCMC only recently began using its supervision powers and there is insufficient evidence of the effectiveness of this activity; and (3) the Ministry of Development/Insurance Directorate has yet to put its supervision powers to use in the AML/CFT arena.

3. Preventive Measures - Designated non-Financial Business and Professions

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The 2007 FATF report found that Greece is non-compliant with R 12 on CDD and record keeping obligations for DNFBPs. According to the FATF mutual evaluation, the AML Law has imposed AML/CFT obligations on certain categories of DNFBP's since 1995, including real estate agents, casinos, chartered accountants and auction houses, whenever the transaction value exceeds EUR 1,500. However, the evaluation highlights some key shortcomings in Greece's adherence to R 12. For example, the main deficiencies noted in the AML/CFT preventative measures applicable to financial institutions (as set out in R 5, R 6, R 8 and R 11) apply also to DNFBPs as stipulated by the AML Law. Other deficiencies include the following: (1) Trust and Company Service Providers (TCSPs) are not covered by the AML Law; (2) the AML Law covers internet casinos but there is no action taken in practice; and (3) despite DNFBPs being technically subject to various provisions of the AML Law, practical application is extremely limited.

On R 16 about STRs for DNFBPs, Greece is rated as non-compliant. Similarly, concerning R 24 about DNFBP regulation, supervision and monitoring, the 2007 FATF mutual evaluation rates Greece as non-compliant. Primarily, as with R 12, the evaluation notes that the main deficiencies in the AML/CFT preventative measures applicable to financial institutions also apply to DNFBPs as stipulated by the AML Law. Furthermore, the FATF report observes that, despite DNFBPs being covered by the AML Law, in practice, nothing has been done to implement the provisions within DNFBPs. Also, "there are insufficient detailed requirements concerning the implementation of internal controls" (p. 176). Regarding R 24, the FATF report noted that Greece lacks designated supervisors for the DNFBPs. In addition, while most DNFBPs are covered under the AML Law, there is a paucity of effective supervision.

4. Legal Person and Arrangements & Non-Profit Organizations

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The 2007 FATF mutual evaluation reports that Greece is non-compliant with R 33 relating to legal persons and access to beneficial ownership and control information. The FATF report attributes this primarily to Greek law not requiring AML/CFT obligated entities to collect or provide information on beneficial ownership and ultimate control of legal persons. In addition, access to information on beneficial ownership and control of legal persons is often not timely and sometimes completely unavailable. Finally, the FATF report observes that there is lack of adequate measures to ensure transparency as to the shareholders of corporations that have issued bearer shares.

Recommendation 34 on legal arrangements and beneficial owners is not applicable to Greece as trusts are not recognized under Greek law. On SR VIII relating to non-profit organizations, the mutual evaluation finds Greece non-compliant because Greece has not implemented any of the requirements set out in SR VIII. According to the 2008 U.S. DoS report, the Greek authorities "[do] not view charitable organizations as vulnerable to terrorist financing or money laundering and [do] not actively monitor such entities for these crimes."

5. National and International Co-operation

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The 2007 FATF report finds Greece partially compliant with R 31 on national cooperation and non-compliant with R 32 on statistics. The mutual evaluation notes that the MEF is responsible for coordinating the activities of the supervisory authorities. However, regarding the rating assigned to R 31, the FATF report states that "there are no effective mechanisms in place which would enable the [Hellenic Police, YPEE, the Hellenic Customs Service, the CC], and other competent authorities (e.g., regulators) to coordinate domestically with each other, and together implement a national policy to combat [money laundering and terrorist financing]" (p. 12). However, on July 17 2008, the Greek government tabled a bill in Parliament to upgrade the mechanisms used in Greece to prevent and suppress money laundering and terrorist financing. Regarding R 31, the bill provides for the formation of a Committee for Combating Money Laundering and Terrorist Financing to be chaired by a senior public prosecutor on active duty selected by a decision of the Supreme Judicial Council. The primary task of the new body would be to ensure the necessary cooperation between the Committee, ordinary Justice, and the Public Prosecution Authorities.

Pertaining to R 32 on statistics, the FATF report notes several deficiencies, notably (1) Greece does not review its AML/CFT system on a regular basis; (2) there are no statistics on the number of requests made or received by/from foreign FIUs; and (3) Greek authorities do not have any statistics on Money Laundering/Financing on Terrosim investigations, prosecutions and convictions, and on property frozen, seized and confiscated.

The 2007 mutual evaluation rates Greece as partially compliant with R 35 regarding the ratification of international conventions, and partially compliant with SR I on implementing UN instruments. According to the U.S. DoS report, Greece is a party to the 1988 UN Drug Convention (the Vienna Convention) and the UN International Convention for the Suppression of the Financing of Terrorism. Greece is signatory to the UN Convention against Transnational Organized Crime (the Palermo Convention) and to the UN Convention against Corruption, but has not yet ratified them. Also, the CC belongs to the Egmont Group. Most importantly regarding R 35, the FATF report notes that, as of the release of the report in June 2007, Greece's implementation of the Palermo Convention is undermined by the money laundering offence being too limited and that self-laundering is not properly criminalized in Greece. Pertaining to Greece's implementation of the Terrorist Financing Convention, the FATF report states that the penalties are not dissuasive. The mutual evaluation also highlights several weaknesses in Greece's compliance with SR I. For example, the report states that, regarding the implementation of the Terrorist Financing Convention, Greece's CDD requirements are inadequate and the implementation of STR obligations is not fully effective. Pertaining to the implementation of S/RES/1267(1999) and S/RES/1373(2001), the FATF mutual evaluation notes that Greece does not currently allow freezing of terrorist assets without delay.

According to the 2007 FATF report, Greece is largely compliant with R 36 concerning Mutual Legal Assistance (MLA). The 2008 U.S. DoS report notes that Greece exchanges information on money laundering through its mutual legal assistance treaty with the United States since 2001. Furthermore, according to the report, "Greece has signed bilateral police cooperation agreements with twenty countries, including the United States." Greece is largely compliant with R 37 on dual criminality and largely compliant with R 38 pertaining to MLA on confiscation and freezing as noted in the 2007 FATF report. With regards to SR V on international cooperation, the mutual evaluation rates Greece as largely compliant. The evaluation also adjudged Greece to be largely compliant on R 39 relating to extraditions. Finally, on R 40 pertaining to other forms of international co-operation, Greece is rated as partially compliant. The FATF mutual evaluation cites several weaknesses in Greece's compliance with R 40, namely that "due to a lack of personnel and technical resources and limited database access, there is an issue of effectiveness with regard to the information exchange of the FIU with foreign authorities on AML matters" (p. 180).