Browse Profiles > Netherlands > Core Principles for Effective Banking Supervision
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Netherlands

Core Principles for Effective Banking Supervision

Summary
The 2007 International Monetary Fund (IMF) Article IV report notes that the banking sector in the Netherlands is generally strong and stable, with a capacity to withstand adverse macroeconomic shocks. The report commends the country's risk-oriented, cross sectoral supervisory framework, which represents international best practice. The IMF, in 2004, conducted a detailed assessment of the Netherlands banking supervision practices against the Basel Core Principles (BCPs) for Effective Banking Supervision and concluded that the Netherlands complied to a very high degree with the BCPs. The assessment also noted that many of its recommendations were, according to the Netherlands' authorities, expected to be addressed in the bill on financial supervision that came into force in 2007 as the Financial Supervision Act. Despite the positive assessment by the IMF in 2004 and consequent reports indicating the overall strong financial sector in the Netherlands, there is scant information publicly available addressing the effectiveness of the Act in implementing the BCPs. According to Dutch central bank (De Nederlandsche Bank, or DNB) website the Act is the current law governing financial supervision in the country. The Financial Supervision Act replaced earlier laws pertaining to financial supervision in the country, specifically the Act on the Supervision of the Credit System 1992 for the banking sector. The 2007 IMF report applauds the Netherlands as a frontrunner in implementing international standards such as Basel II and Solvency II, as well as International Financial Reporting Standards.

    General Overview

    The 2007 International Monetary Fund (IMF) Article IV report notes that the financial and banking sectors in the Netherlands are strong and stable overall, with a capacity to withstand adverse macroeconomic shocks. The report commends the country's risk-oriented, cross sectoral supervisory framework, which it finds as representing "international best practice" (p. 1). The IMF, in 2004, conducted a Detailed Assessment of Standards and Codes (DASC) on Netherlands banking supervision practices and concluded that, of the 30 Basel Core Principles (BCPs) (including the 6 sub principles for Principle 1), the Netherlands complied with 24 and largely complied with the rest BCPs. The 2004 IMF assessment made a few recommendations that, according to the IMF's 2006 Article IV Consultation report, the Netherlands has significantly progressed toward implementing. In 2004, at the time of the IMF's 2004 Financial System Stability Assessment (FSSA), the laws governing financial sector supervision in the Netherlands were primarily the Bank Act of 1998 and the Act on the Supervision of the Credit System of 1992 (Wtk). The FSSA addressed the effectiveness of these laws. However, in 2007, the Financial Supervision Act (Wft) came into effect and replaced the 1992 Wtk. Since then there has been little information publicly available addressing the Wft's effectiveness in implementing the BCPs. However, in the IMF's 2004 DASC, the Netherlands' authorities indicated that the country would fully comply with several BCPs as and when the Wft took effect.
    The IMF's 2004 DASC notes that the rule of law exists in the Netherlands, along with an updated legal framework and efficient judicial system. The supervisory authority, which is the Dutch central bank or DNB, faces no political or industry interference in the exercise of its supervisory powers. The accounting and auditing rules and practices comply with international standards and European Union (EU) directives, and are in the process of further harmonization with the updated International Financial Reporting Standards (IFRSs) along with the general EU-level implementation in 2005. The 2004 DASC recommends clarifying the supervisory responsibilities and objectives; strengthening supervisory independence of the DNB; setting explicit prudential rules on integrity; extending fitness criteria to senior management; improving transparency in the licensing process; establishing prudential reporting and supervision on a solo as well as consolidated basis; designating a money laundering reporting officer at a senior level; adopting a more structured approach to risk assessment; and formalizing supervisory information exchange with foreign counterparts.
    Both the 2007 Article IV report and the 2004 Detailed Assessment by the IMF point to the unique nature of the Netherlands financial supervisory practices whereby the DNB is the overall prudential supervisor, while the Financial Markets Authority (AFM) supervises market conduct of all financial institutions. This institutional structure has provided bedrock to financial stability, which goes deeper than the adequate capital adequacy of banks or their profitability. The integration of macro-prudential financial stability with risk-based supervision framework (the Financial Institutions Risk Analysis Method (FIRM)) of the DNB has evidently benefited both the supervisors and the supervised institutions. The AFM has also designed self-assessment templates for institutions to evaluate their market conduct, and by which it prioritizes supervision. Further, the two supervisors coordinate supervision under the terms of a covenant and take a consultative approach to decision-making. Also, according to the IMF's 2007 report, the Dutch financial sector leads most other countries in implementing new standards for capital adequacy, risk management, and auditing, including Basel II, Solvency II, and IFRSs.
    The 2006 IMF Article IV report provides statistics on the Dutch banking sector as of 2005. Accordingly, there are 94 banks, of which 64 are private commercial banks, one is a state-owned bank, and there are 24 foreign-owned subsidiaries. There are also 32 branches of foreign banks in the country. The sector is highly concentrated, which can be inferred from the fact that three banks own three-fourths of the total assets. The total assets amount to €2,767,526 million, of which foreign owned subsidiaries account for €249,948 million. The foreign branches own €34,523 million in assets.


    The Principles

    1. (1) Clear responsibilities and objectives for each supervisory agency.

    The IMF's 2004 Detailed Assessment notes that the Netherlands is largely compliant with this principle. Further, the 1998 Bank Act and the 1992 Wtk spell out the duties and powers of the DNB as the prudential supervisor of credit institutions. A Covenant included in the Credit System Supervision Manual and elaborated further in a policy rule provides for information sharing between the three financial sector supervisors, the DNB, the AFM, and the Pensions and Insurance Supervisory Authority (PVK ). However, the 2004 Detailed Assessment recommends greater theoretical as well as practical clarity of regulatory responsibilities, their professed objectives, and cooperative arrangements. The FSSA also calls for new legislation in order to reflect the shift from a sectoral supervisory framework to a functional framework. The 2004 FSSA observes that the new banking law would address these issues and subsequently, in 2007, the Wft came into effect. However, there is little information publicly available addressing the Wft's effectiveness in implementing this principle.

    1.(2) Operational independence and adequate resources.

    According to the 2004 IMF Detailed Assessment, the Netherlands is fully compliant with this principle. The assessment, however, recommends further improvements in the independence and transparency of the supervisory authority, namely the DNB, and also notes that, once the new banking law, the Wft, comes into effect this issue will be completely addressed. The Wft came into force in January 2007, but there is as yet little information publicly available addressing the Wft's effectiveness in implementing this principle.

    1.(3) A suitable legal framework for authorization and ongoing supervision.

    The IMF's 2004 Detailed Assessment notes that the Netherlands is fully compliant with this principle. However the report was based on the legal structure prevailing in the Netherlands in 2004, which subsequently changed with the enactment of the Wft in 2006, and there is little information publicly available addressing the Wft's effectiveness in implementing this principle.

    1.(4) A suitable legal framework to address compliance with laws as well as safety and soundness concerns.

    According to the 2004 IMF Detailed Assessment, the Netherlands is fully compliant with this principle. However the report was based on the legal structure prevailing in the Netherlands in 2004, which subsequently changed with the enactment of the Wft in 2006, and there is little information publicly available addressing the Wft's effectiveness in implementing this principle.

    1.(5) Legal protection for supervisors.

    Per the IMF's 2004 Detailed Assessment, the Netherlands is fully compliant with this principle. The report further notes that though there is no legal basis for the protection of supervisors, the Civil Code, as confirmed in court precedents, ensures protection of supervisory staff for actions carried out in good faith and there is no need for further provisions in other laws.

    1.(6) Arrangement for sharing of information between supervisors and protection of confidentiality of shared information.

    The IMF's 2004 Detailed Assessment notes that the Netherlands is fully compliant with this principle. However the report was based on the legal structure prevailing in the Netherlands in 2004, which subsequently changed with the enactment of the Wft in 2006, and there is little information publicly available addressing the Wft's effectiveness in implementing this principle. Further, according to the same report, the Covenant between the DNB, the AFM, and the PVK lays down domestic cooperation, while the DNB has also concluded various Memoranda of Understanding (MoUs) and other agreements with foreign supervisors for information sharing. The 2006 IMF Article IV report mentions one of the recommendations made in the 2004 Detailed Assessment, which called for the continuation of the development of the framework for dealing with crisis situations through further cooperation with foreign supervisors. The 2006 report states that the DNB has engaged in bilateral discussions and coordination at the EU level and has also concluded an MoU with the Belgian financial sector supervisor and Belgian central bank on crisis management in the case of financial institutions having substantial operations in both countries.

    2. Clearly defined permissible activities for banks and control of the use of the word 'bank'.

    According to the IMF's 2004 Detailed Assessment, the Netherlands is compliant with this principle. However the 2004 report was based on the legal structure prevailing in the Netherlands in 2004, which subsequently changed with the enactment of the Wft in 2006, and there is little information publicly available addressing the Wft's effectiveness in implementing this principle.

    3. Criteria for structure, directors, operating plan, controls, financial condition and capital base.

    Per the IMF's 2004 Detailed Assessment, the Netherlands is largely compliant with this principle. However the report was based on the legal structure prevailing in the Netherlands in 2004, which subsequently changed with the enactment of the Wft in 2006, and there is little information publicly available addressing the Wft's effectiveness in implementing this principle.

    4. Authority to review and reject transfer of ownership.

    The Netherlands is largely compliant with this principle according to the 2004 Detailed Assessment by the IMF. However the report was based on the legal structure prevailing in the Netherlands in 2004, which subsequently changed with the enactment of the Wft in 2006, and there is little information publicly available addressing the Wft's effectiveness in implementing this principle.

    5. Authority to review major acquisitions and investments.

    The IMF's 2004 Detailed Assessment notes that the Netherlands is compliant with this principle. However the report was based on the legal structure prevailing in the Netherlands in 2004, which subsequently changed with the enactment of the Wft in 2006, and there is little information publicly available addressing the Wft's effectiveness in implementing this principle.

    6. Minimum capital adequacy requirements (meet Basle Capital Accord for internationally active banks).

    The IMF's 2004 Detailed Assessment notes that the Netherlands is compliant with this principle. However the report was based on the legal structure prevailing in the Netherlands in 2004, which subsequently changed with the enactment of the Wft in 2006, and there is little information publicly available addressing the Wft's effectiveness in implementing this principle. The 2006 annual report of the DNB informs that the Dutch banking sector is sound, with an 11.6 percent BIS ratio (a measure of the risk based solvency of banks). However, their profitability has been facing pressure from higher provisioning and lower demands for mortgage loans.

    7. A method exists for the evaluation of procedures related to loans, investments and portfolio management.

    The 2004 Detailed Assessment by the IMF notes that the Netherlands is fully compliant with this principle. The Regulation on Organization and Control (ROC) and other guidelines clearly and comprehensively spell out the requirements for authorized banks to have risk control policies and sound business practices in place. The DNB also conducts on-site inspections to assess the formulation and implementation of the risk control measures at banks.

    8. Policies, practices and procedures for evaluating the quality of assets and the adequacy of loan loss provisions and reserves.

    The Netherlands is fully compliant with this principle, per the 2004 Detailed Assessment by the IMF. According to the same report "section 38 of the ROC stipulates that each bank must have in place an adequate information system for the systematic measurement, monitoring and documentation of all credits" (p. 19). The loan-loss provisioning system in the Netherlands, as in many other EU countries, is principle- rather than rule-based. Therefore the DNB has no formal rules on this subject, but uses this system as a tool to assess the asset quality of a bank. The DNB also conducts on-site inspections to assess the credit quality of institutions and imposes general provisioning levels contrary to the external auditor's recommendations.

    9. Prudential limits and management information system on concentration of exposure.

    The IMF's 2004 Detailed Assessment notes that the Netherlands is compliant with this principle. However the report was based on the legal structure prevailing in the Netherlands in 2004, which subsequently changed with the enactment of the Wft in 2006, and there is little information publicly available addressing the Wft's effectiveness in implementing this principle.

    10. Arm's length rule and monitoring for connected lending.

    Per the IMF's 2004 Detailed Assessment, the Netherlands is compliant with this principle. According to the same report, the ROC and the Risk Assessment Guidelines give particular importance to the issue of connected lending. However, the 2004 assessment by the IMF recommends connected lending limits to be applied to solo entities.

    11. Policies and procedures for country risk and transfer risk.

    The IMF's 2004 Detailed Assessment notes that the Netherlands is compliant with this principle. However the report was based on the legal structure prevailing in the Netherlands in 2004, which subsequently changed with the enactment of the Wft in 2006, and there is little information publicly available addressing the Wft's effectiveness in implementing this principle.

    12. Measuring and monitoring market risk. Limit and/or specific capital charge on market risk exposure.

    Per the IMF's 2004 Detailed Assessment, the Netherlands is compliant with this principle. According to the same report per the ROC, "each authorized bank in the Netherlands is required to have clearly formulated policies that are aimed at risk control and sound business practices" (p. 22). The DNB "uses a comprehensive range of tools to ensure that the banks are able to measure, monitor and control market risk" (p. 23), including the use of capital market specialists to review the banks own internal risk models. Their policies on the need to impose a capital charge on such activities reflect the evolving nature of financial markets.

    13. Comprehensive risk management processes.

    The IMF's 2004 Detailed Assessment notes that the Netherlands is compliant with this principle. However the report was based on the legal structure prevailing in the Netherlands in 2004, which subsequently changed with the enactment of the Wft in 2006, and there is little information publicly available addressing the Wft's effectiveness in implementing this principle.

    14. Adequate internal controls.

    The IMF's 2004 Detailed Assessment notes that the Netherlands is compliant with this principle. However the report was based on the legal structure prevailing in the Netherlands in 2004, which subsequently changed with the enactment of the Wft in 2006, and there is little information publicly available addressing the Wft's effectiveness in implementing this principle. The DNB has comprehensive policies requiring banks to have sound internal controls and appropriate corporate governance procedures. The 2004 Detailed Assessment, however, recommends the strengthening of non-executive group functions for all banks; and the internal audit function in all banks to report to an Audit Committee.

    15. Strict "know-your-customer" rules and high ethical and professional standards.

    According to the IMF's 2004 Detailed Assessment, the Netherlands is largely compliant with this principle. However the FSSA was based on the legal structure prevailing in the Netherlands in 2004, which changed with the enactment of the Wft in 2006, and there is little information publicly available addressing the Wft's effectiveness in implementing this principle. The 2004 Detailed Assessment notes that "according to section 69 of the ROC, banks are required to have an independent compliance function in place. The compliance function monitors, first, compliance with internal standards, rules and codes of conduct and secondly, the realization of rectification as a result of detected deficiencies and control failures" (p. 26). The 2004 IMF ROSC on Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) finds that the respective financial sector regulators are charged with the responsibility of oversight of the financial institutions' compliance with AML/CFT laws and regulations, and that they have adequate risk management tools to analyze risks associated with money laundering and terrorist financing (ML/TF). Further, the DNB has issued the Basel Committee Customer Due Diligence (CDD) paper to credit institutions in 2002 asking them to benchmark their CDD practices with the requirements set out in the paper. An additional explanation on the paper in 2003 served as further CDD guidelines, though the ROSC avers that they are not comprehensive.

    The 2006 IMF Article IV report finds that the Netherlands has made progress in some aspects since the publication of its 2004 "Detailed Assessment." For example, customer identification has been strengthened with the enforcement of the regulation on CDD measures at institutions since 2004, and obligations on disclosure of information have been expanded with the amendment to the Disclosure of Unusual Transactions (Services) Act in 2006. The 2007 U.S. DoS report notes that all supervised entities must report suspicious transactions of any amount, as well as cash transactions over €15, 000 to the country's Financial Intelligence Unit (FIU). After subsequent amendments to the money laundering laws, the list of reporting entities in the Netherlands has expanded to include banks, bureaux de change, life insurance companies, securities firms, stock brokers, credit card companies, financing companies, and a wide range of non-financial entities. The report further notes that Dutch law mandates financial institutions to maintain transaction records for at least five years after the termination of the relationship. Also no secrecy laws prohibit banks from disclosing client information to their supervisors.

    16. Effective supervisory system consisting of on-site and off-site supervision.

    The IMF's 2004 Detailed Assessment notes that the Netherlands is compliant with this principle. However the report was based on the legal structure prevailing in the Netherlands in 2004, which subsequently changed with the enactment of the Wft in 2006, and there is little information publicly available addressing the Wft's effectiveness in implementing this principle.

    17. Regular contact with bank management and understanding of bank's operations.

    The IMF's 2004 Detailed Assessment notes that the Netherlands is compliant with this principle. Further, it finds that there is comprehensive contact and communication of the supervisors with bank management at all levels. Nonetheless, the 2004 Detailed Assessment addressed the legal structure prevailing in the Netherlands in 2004, which subsequently changed with the enactment of the Wft in 2006, and there is little information publicly available addressing the Wft's effectiveness in implementing this principle.

    18. Analytical reports and statistical returns on solo and consolidated basis.

    According to the IMF's 2004 Detailed Assessment, the Netherlands is compliant with this principle. However the report was based on the legal structure prevailing in the Netherlands in 2004, which subsequently changed with the enactment of the Wft in 2006, and there is little information publicly available addressing the Wft's effectiveness in implementing this principle.

    19. Independent validation of supervisory information through on-site examination or external auditors.

    Per the IMF's Detailed Assessment in 2004, the Netherlands is compliant with this principle. However the report was based on the legal structure prevailing in the Netherlands in 2004, which subsequently changed with the enactment of the Wft in 2006, and there is little information publicly available addressing the Wft's effectiveness in implementing this principle.

    20. Ability to supervise on a consolidated basis.

    The IMF's 2004 Detailed Assessment notes that the Netherlands is compliant with this principle. However the report was based on the legal structure prevailing in the Netherlands in 2004, which subsequently changed with the enactment of the Wft in 2006, and there is little information publicly available addressing the Wft's effectiveness in implementing this principle.

    21. Consistent accounting policies and practices that provide a true and fair view of the financial condition of the bank.

    According to the IMF's 2004 Detailed Assessment, the Netherlands is compliant with this principle. According to the same report, "pursuant to company law and the Wtk, the financial record-keeping systems of banks and the data these systems produce must be reliable" (p. 33). However the 2004 Detailed Assessment was based on the legal structure prevailing in the Netherlands in 2004, which subsequently changed with the enactment of the Wft in 2006, and there is little information publicly available addressing the Wft's effectiveness in implementing this principle.

    22. Adequate supervisory measures to ensure timely corrective action.

    The IMF's 2004 Detailed Assessment notes that the Netherlands is largely compliant with this principle. However the report was based on the legal structure prevailing in the Netherlands in 2004, which subsequently changed with the enactment of the Wft in 2006, and there is little information publicly available addressing the Wft's effectiveness in implementing this principle.

    23. Banking supervisors must practice global consolidated supervision over their internationally-active banking organizations.

    The IMF's 2004 Detailed Assessment notes that the Netherlands is largely compliant with this principle. However the report was based on the legal structure prevailing in the Netherlands in 2004, which subsequently changed with the enactment of the Wft in 2006, and there is little information publicly available addressing the Wft's effectiveness in implementing this principle. Per the Detailed Assessment, the consolidated supervision of the DNB is effective, and it has adequate risk-assessment resources for monitoring larger global banking groups. It receives prudential returns from banks on a regular basis, and has a flexible risk model to encompass both single entity as well as group-wide assessments. The DNB also supervises overseas branches of Dutch banks through regular on-site visits along with some reliance on overseas regulators.

    24. International exchange of information with other supervisors.

    According to the IMF's 2004 Detailed Assessment, the Netherlands is largely compliant with this principle. However the report was based on the legal structure prevailing in the Netherlands in 2004, which subsequently changed with the enactment of the Wft in 2006, and there is little information publicly available addressing the Wft's effectiveness in implementing this principle. Per the Detailed Assessment, the 1992 Wtk allows the DNB to exchange information with foreign financial sector supervisors, with conditions on secrecy and use of information. The DNB has also signed MoUs with all EU countries as well as relevant third countries on the supervision of foreign subsidiaries and branches and exchange of information, and is preparing new MoUs with other countries. The 2004 Detailed Assessment also observes that the DNB has "an open and cooperative approach to sharing information with overseas supervisors" (p. 37), and engages in regular dialogue with banks with overseas operations. In the situation of potentially insufficient flow of information from host countries, the DNB can prohibit setting up of foreign subsidiaries of Dutch banks in such countries.

    25. Supervision of local operation of foreign banks and information sharing with home country supervisors.

    The IMF's 2004 Detailed Assessment notes that the Netherlands is largely compliant with this principle. However the report was based on the legal structure prevailing in the Netherlands in 2004, which subsequently changed with the enactment of the Wft in 2006, and there is little information publicly available addressing the Wft's effectiveness in implementing this principle. According to the Detailed Assessment, under the 1992 Wtk, "local branches and subsidiaries of foreign banks are subject to the same legal and supervisory regime as are domestic banks" (p. 37). However, under the terms of mutual recognition agreements, home country control principle applies to branches of EU licensed banks, which exempts them from capital adequacy supervision on a solo basis by the DNB, though not from its liquidity requirements. Further, the DNB evaluates the home country supervisory adequacy and if it on a consolidated basis before granting license to non-EU branches or subsidiaries, and discourages branches from countries with a low standard of supervision. The DNB requires written approval from the home supervisor before granting permission to establish a foreign branch or subsidiary.

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    Sources of Assessment

    De Nederlandsche Bank website. Last updated on January 1, 2007. Accessed on January 11, 2008. (DNB website)

    International Monetary Fund, "Kingdom of the Netherlands - Detailed Assessments of Standards and Codes," Country Report No. 04/310, Washington, D.C.: IMF, September 2004. Available from International Monetary Fund website. Accessed on January 11, 2008. (IMF 2004a)

    International Monetary Fund, "The Kingdom of the Netherlands - Netherlands: Financial System Stability Assessment, including Reports on the Observance of Standards and Codes on the following topics: Banking Supervision, Securities Regulation, Insurance Regulation, Corporate Governance, and Payment Systems, Securities Settlement Systems, and Anti-Money Laundering/Combating the Financing of Terrorism," Country Report No. 04/312, Washington, D.C.: IMF, 2004. Available from International Monetary Fund website. Accessed on January 11, 2008. (IMF 2004b)

    International Monetary Fund, "Kingdom of the Netherlands - Netherlands: 2006 Article IV Consultation - Staff Report; Staff Statement; and Public Information Notice on the Executive Board Discussion," Country Report No. 06/283, Washington, D.C.: IMF, July 2006. Available from International Monetary Fund website. Accessed on January 11, 2008. (IMF 2006)

    International Monetary Fund, "Kingdom of the Netherlands - Netherlands: 2007 Article IV Consultation - Staff Report; Staff Statement; Public Information Notice on the Executive Board Discussion; and Statement by the Executive Director for the Kingdom of the Netherlands - Netherlands," Country Report No. 07/216, Washington, D.C.: IMF, June 2007. Available from International Monetary Fund website. Accessed on January 11, 2008. (IMF 2007)

    Relevant Organizations

    Financial Markets Authority - Autoriteit Financiële Markten (AFM)

    Dutch Central Bank - De Nederlandsche Bank (DNB)

    Ministry of Finance - Ministerie van Financiën (MoF)

    Ministry of Justice - Ministerie van Justitie (MvJ)

    Office for the Disclosure of Unusual Transactions, Ministry of Justice - Meldpunt Onjebruikelijke Transacties (MOT)

    Pensions and Insurance Supervisory Authority of the Netherlands - Pensioen en Verzekeringskamer (PVK) (merged in October 2004 with the DNB)

    Proceeds of Crime Office, Public Prosecution Service (BOOM)



    Relevant Legislation/Regulation

    Financial Supervision Act, 2006 - Wet op het financieel toezicht, 2006

    Act on the Supervision of the Credit System, 1992 - Wet toezicht kredietwezen, 1992 (repealed)

    Bank Act, 1998 - Bankwet, 1998 (with amendments through 2004)

    Risk Assessment Guidelines

    Credit System Supervision Manual

    Regulation on Organization and Control

    Civil Code, 1992

    European Union Capital Requirements Directives 2006/48/EC and 2006/49/EC, 2006



    Supplementary Sources

    De Nederlandsche Bank, "Annual Report 2004," Amsterdam, Netherlands: DNB, May 2005. Available from De Nederlandsche Bank website. Accessed on January 11, 2008. (DNB 2005)

    De Nederlandsche Bank, "Annual Report 2006,"" Amsterdam, Netherlands: DNB, April 2007. Available from De Nederlandsche Bank website. Accessed on January 11, 2008. (DNB 2007)

    International Monetary Fund, "Kingdom of the Netherlands - Netherlands: 2005 Article IV Consultation - Staff Report; Staff Statement; and Public Information Notice on the Executive Board Discussion," Country Report No.05/226, Washington, D.C.: IMF, July 2005. Available from International Monetary Fund website. Accessed on January 11, 2008. (IMF 2005)

    U.S. Department of State, Bureau for International Narcotics and Law Enforcement, "International Narcotics Control Strategy Report," March 2007. Available from U.S. Department of State website. Accessed on January 11, 2008. (U.S. DoS 2007)
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