According to the Financial Action Task Force's (FATF) Third Mutual Evaluation Report for Norway on Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) released in June 2005, Norway is fully compliant with 13 FATF Recommendations, largely compliant with 15 Recommendations and 3 Special Recommendations, partially compliant with 8 Recommendations and 4 Special Recommendation, and non compliant with 2 Recommendations and 2 Special Recommendations. The other two recommendations (Recommendation 9 pertaining to third parties and introduced business, and Recommendation 34 pertaining to legal arrangements - beneficial ownership, and control information) are not applicable in the Norwegian context. The Norwegian Penal Code criminalizes both money laundering and terrorist financing. The 2003 Money Laundering Act has further strengthened the AML/CFT regulatory framework in Norway. The Money Laundering Team (MLT), which is housed in the National Authority for Investigation and Prosecution of Economic and Environmental Crime (ØKOKRIM), is Norway's financial intelligence unit (FIU). The 2006 annual report by ØKOKRIM indicates, however, that the FIU does not go by the name of Money Laundering Team anymore. The 2006 Financial Supervisory Authority of Norway (FSAN) annual report states that the FSAN supervises institutions' compliance with the Norwegian Money Laundering Act of 2003, and prioritizes supervision in line with the FATF recommendations. The FSAN report titled "Strategy 2006-2010" attests that the FSAN AML/CFT supervisory rules are in line with the European Union requirements as well as international best practices. Further, the 2006 annual report of the ØKOKRIM states that the 2006 budget of Norway allocated additional funds to the ØKOKRIM to enhance its AML efforts. The ØKOKRIM hopes that these steps will revamp its intelligence and investigative powers and arrangements and alleviate the inadequacies of equipment, analytical tools, and financing in the FIU that were identified by the FATF report.
General Overview
According to the Financial Action Task Force's (FATF) Third Mutual Evaluation Report for Norway on Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) released in June 2005, Norway is fully compliant with 13 of the FATF 40 Recommendations and 9 Special Recommendations (SRs) promulgated in 2003, largely compliant with 15 Recommendations and 3 SRs, partially compliant with 8 Recommendations and 4 SRs, and non compliant with 2 Recommendations and 2 SRs. The other two recommendations -- Recommendation 9 pertaining to third parties and introduced business; and Recommendation 34, pertaining to legal arrangements, beneficial ownership, and control information -- are not applicable in the Norwegian context.
The 2006 Financial Supervisory Authority of Norway (Kredittilsynet, or FSAN) annual report states that the FSAN supervises institutions' compliance with the Norwegian Money Laundering Act of 2003, and prioritizes supervision in line with the FATF recommendations. The FSAN report titled "Strategy 2006-2010" attests that the FSAN supervisory rules with regard to AML/CFT are aligned with the European Union (EU) requirements as well as international best practices. The 2005 U.S. Department of State (DoS) report finds that the FSAN "monitors the financial institutions, issues warnings, forwards the consolidated United Nations Security Council Resolution (UNSCR) 1267/1390 list of terrorist entities and individuals to financial institutions, and issues orders to freeze assets and funds." Further, it monitors the institutions through on-site inspections for their compliance with regulations and is taking steps to bring charitable organizations under the purview of reporting requirements.
The 2005 annual report (published in 2006 and henceforth referred to as the 2006 ØKOKRIM report) of the National Authority for Investigation and Prosecution of Economic and Environmental Crime's (ØKOKRIM) Money Laundering Team (MLT) states that the 2003 Act on Measures to Combat the Laundering of Proceeds of Crime (Money Laundering Act) came into force in January 2004, and "is a continuation of section 2-17 of the 1988 Financial Institutions Act, which mandates that financial institutions (including banks, brokerages and insurance companies) report suspicious transactions to ØKOKRIM" (p. 3). The 2003 Act also covers lawyers, estate agents, auditors, accountants, and dealers of expensive objects who receive cash payments of Norwegian krone (NOK) 40,000 or more, and includes reporting with regard to terrorist financing. Per the 2006 ØKOKRIM report, the ØKOKRIM was established in 1989 and "has a dual role: it is a specialist agency within the police and a national prosecuting authority. The formal rules about ØKOKRIM can be found in chapter 35 of the Prosecution Instructions" (p. 5). The MLT, which is a part of the ØKOKRIM, is the Norwegian Financial Intelligence Unit (FIU) and has been a member of the Egmont Group since 1995. The 2006 annual report by ØKOKRIM indicates, however, that the FIU does not go by the name of Money Laundering Team anymore. The same report also discloses that the 2006 budget of Norway allocated additional funds to the ØKOKRIM to enhance its AML efforts by the formation of a new team called the Stolen Goods and Money Laundering Team, the hiring of an investigation analyst, developing a more advanced computer system -- the ELMO -- for suspicious transaction report (STR) processing, and introducing Indicia, the police's new intelligence system. The ØKOKRIM is also in the midst of developing a new intelligence strategy for the police. The ØKOKRIM 2005 Annual Report states that these measures have been in response to the FATF recommendations and hopes that they will revamp its intelligence and investigative powers and arrangements and alleviate the inadequacies in the MLT identified by the FATF report, pertaining to its equipment, analysis tools and finances and summarized in the 2005 annual report of the MLT.
Per the 2005 U.S. DoS report, the Norwegian Penal Code criminalizes money laundering. Further, Section 34 of the Penal Code establishes mandatory confiscation of criminal assets by the ØKOKRIM "unless a court finds that the confiscation is unreasonable," and allows for civil as well as criminal forfeiture, with the proceeds going to the State. Norwegian laws do not allow for narcotics-related asset sharing with other countries. Section 147 (A-B) of the Penal Code was passed in June 2002 and criminalizes terrorism financing, in conformity with the UN International Convention for the Suppression of the Financing of Terrorism. Further, Norway also adopted the EU's Common Position on the Application of Specific Measures to Combat Terrorism in 2002. The 2005 U.S. DoS report also finds that Norway has bolstered its AML legislation to conform to the 2003 FATF recommendations by the enactment of the Money Laundering Act of 2003, which "strengthens registration requirements, broadens the obligation to report suspicious transactions, and makes negligent contravention of the act a criminal offense." However, the 2005 International Monetary Fund (IMF) Report on the Observance of Standards and codes (ROSC) finds that the Act does not fully incorporate the 2003 FATF recommendations relating to preventive measures for financial institutions. The ROSC states that "Recent AML/CFT priorities in Norway have been to increase the effectiveness of measures to detect, prosecute, and confiscate proceeds of crime; enhance international co-operation; competence building; comply with the current EU Money Laundering Directive; and train the 27 specialized economic crime units" (p. 1). The 2005 U.S. DoS report recommends that Norway continue strengthening its AML/CFT legal framework, with particular effort to adopt "laws that would allow the sharing of seized assets with third party jurisdictions that assisted in the conduct of the underlying investigation."
The 2005 IMF ROSC states that the financial institutions authorized to operate in Norway are "savings banks, commercial banks, finance companies and mortgage companies; life and non-life insurance companies, e-money institutions, investment firms, security funds management companies, and branches of foreign financial institutions" (p. 1). The ROSC also finds that although foreign exchange offices (i.e. bureaux de change) and money/value transfer service (MVTS) providers are prohibited in Norway, "banks, finance companies, and EEA [European Economic Area] branches of such undertakings are allowed to carry out such financial activities" (p. 1).
The 2005 U.S. DoS report provides AML/CFT statistics for Norway. It finds that the authorities had initiated 292 money laundering investigations as of June 2004; resulting in 200 court convictions and 245 cases of indictments or fines. The report finds that money laundering cases are mostly domestic crime related and not linked to terrorist activities. In 2003, there were 929 confiscation orders for criminal assets and amounted to $24 million. However, the report finds that Norway is not a terrorism hub, and there have been almost no terrorist financing cases, except that under the UNSCR 1267 Sanctions Committee's consolidated list. In total, one bank account with the amount of $1,000 has been frozen since 2003.
The Principles
1. Legal Systems and Related Institutional Measures
According to the 2005 FATF report, under Principle 1, Norway is fully compliant with Recommendations 2, 3, 27 and 28, and SRs II and III; largely compliant with Recommendation 1; and partially compliant with Recommendations 26, 30 and 32 and SRs IX. As noted by the report, the 2003 Norwegian Money Laundering Act does not fully incorporate the revised 40+9 Recommendations issued by the FATF in 2003. However, the customer identification legislative framework is in line with the first and second EU Money Laundering Directives and the FATF recommendations of 1996; and is also intended to be aligned with the third EU Money Laundering Directive once it was finalized. The 2003 Money Laundering Act and the Money Laundering Regulations cover all financial institutions as per the FATF recommendations.
Per the 2005 FATF report, Norway is largely compliant with Recommendation 1 and fully compliant with Recommendation 2 - both relating to the criminalization of money laundering. Section 317 of the Penal Code criminalizes money laundering and includes both drug-related and negligent money laundering. The law, however, does not criminalize self-laundering and money laundering involving only two people. Nevertheless, the FATF notes that "overall, these offences are broad in scope and apply to all crimes" (p. 4). The conviction rate is also high, suggesting effective enforcement. The FATF in its 2005 report finds that there are still few aggravated money laundering cases, and advises Norway to ascertain the reasons, and rectify the situation with better training or legislation.
The 2005 FATF report further finds that Norway is largely compliant with SR II regarding criminalization of terrorist financing. Further, Norway's terrorist financing criminalization is "generally in line with the [United Nations] Terrorist Financing Convention" (p. 5). Section 147b of the Penal Code makes terrorist financing an autonomous offence, covering funds collected with the knowledge that they are to be used for terrorist activities, but not for any purpose by a terrorist organization. There have been no terrorist financing prosecutions in Norway. The FATF recommends that Norway clarify legislation in this area. The 2005 FATF report observes that Norway is fully compliant with Recommendation 3 regarding confiscation, freezing, and seizing of the proceeds of crime, but only partially compliant with SR III regarding freezing of funds used for terrorist financing. Norway has taken successful confiscation and seizure measures, and provides its prosecution authorities a broad range of powers to identify and trace assets of crime. It has also implemented UNSCR S/RES/1267(1999) and UNSCR S/RES/1373(2001) by enabling laws and regulations. However, the scope of these laws is narrow, and the regime lacks clear guidelines to and monitoring of compliance by reporting institutions (RIs), thereby reducing its effectiveness.
Per the 2005 FATF report, Norway is partially compliant with Recommendations 26, 30 and 32 regarding the FIU and its functions. The ØKOKRIM's MLT is Norway's FIU, and it has been a member of the Egmont Group since 1995. The FATF finds that although the MLT meets the legal requirements of Recommendation 26, its effectiveness is in question due to four considerations: (1) technical limitations prevent comprehensive STR analysis; (2) insufficient resources prevent satisfactory handling of STRs; (3) interference of the Control Committee (an independent agency reporting to the Ministry of Finance impacts on the MLT's effectiveness by diverting scarce funds; and (4) the MLT does not fully follow the Egmont Principles of Information Exchange between FIUs. The FATF recommends more fund allocation and technological renovation of the MLT and more training for its staff. The 2005 annual report by the MLT mentions the project launched in 2004 to create an IT-enabled system, ELMO, which aims to receive, process, and analyze large quantities of reports more efficiently and effectively. The 2006 ØKOKRIM annual report states that Norway has allocated additional funds to the ØKOKRIM in 2006 to enhance its AML efforts by the formation of a new Stolen Goods and Money Laundering Team, the hiring of an investigation analyst, developing of ELMO for STR processing, and the introduction of Indicia, the police's new intelligence system. The ØKOKRIM hopes that these steps will revamp its intelligence and investigative powers and arrangements and alleviate the MLT's inadequacies of equipment, analytical tools, and financing that were identified by the FATF report.
According to the 2005 FATF report, Norway is fully compliant with Recommendations 27 and 28 regarding law enforcement authorities and their powers, but only partially compliant with Recommendations 30 and 32 regarding their resources, integrity, training, and statistics. The law enforcement authorities in Norway include the Police Directorate, the Police Security Service (PST), the 27 police districts, the New Kripos and the Police College. They all assist the ØKOKRIM. Police districts have separate teams to combat economic crime, the ØKOKRIM investigates economic crimes including money laundering and terrorist financing; terrorist financing is also investigated by the PST.
The 2005 FATF report finds the investigative and seizure powers to be satisfactory. However, it notes that the MLT is "understaffed, under-resourced, and technologically ill-equipped" (p. 6). Reports are entered and analyzed manually, staff is not trained in the use of the "Analysts Notebook," the management and resources of the MLT are not clearly earmarked, and there is overlap and fragmentation in the oversight of the MLT due to joint involvement of the MoF and the Ministry of Justice and Police (MJP). The advanced training course offered to police officers at the Police College is "not sufficient to meet the need for competence" (FATF 2005, p. 61) for AML investigations, and the ØKOKRIM attracts away many highly trained investigators. Further, Norway's statistic regime leaves much to be desired. Data are inadequate and unreliable. Norway does not keep comprehensive statistics on sanctions for non-compliance of AML/CFT obligations, mutual legal assistance requests, or extradition requests. Also, the FATF discovered that in 2004, due to a technical breakdown, the MLT lost valuable statistical data, bringing the focus on the inadequacy of its data collection mechanisms and the sorry state of its technological systems.
As the 2005 FATF report finds, Norway is partially compliant with SR IX regarding cross border declaration and disclosure. Declaration obligations do not apply to bearer-negotiable instruments. Police and investigating authorities can access transaction logs only in the event of an investigation. Lists of designated persons under UNSCR S/RES/1267 (1999) are made available to custom authorities; however those under UNSCR S/RES/1373 (2001) are not distributed.
According to the 2005 FATF report, under Principle 2, Norway is fully compliant with Recommendations 4, 8, 10, 11, 14, 19, and 21; largely compliant with Recommendations 13, 15, 17, 22, 23, 29, and SR IV; partially compliant with Recommendations 5, 18, 25, 30 and 32, and SR VI; and non-compliant with Recommendations 6, 7, and SR VII. Recommendation 9, pertaining to third parties and introduced business, is not applicable in the Norwegian context, since Norwegian law does not permit reporting institutions to rely on third party reporting or introductory business.
Per the 2005 FATF report, Norway is partially compliant with Recommendation 5 regarding customer due diligence (CDD). The 2003 Money Laundering Act and the Money Laundering Regulations do not fully implement the FATF Recommendations of 2003, although its customer identification measures are in line with the first and second EU Money Laundering Directives and the FATF Recommendations of 1996, and its AML measures cover all financial institutions that must be included per the FATF recommendations. However, the FATF notes that customer identification requirements are directed towards the banking sector, and do not take into account the differences in the business models of other non-bank sectors. Norway also intended to incorporate the third EU Money Laundering Directive once it was adopted (the Directive came into effect in 2005). Risk categories of customers and products are also assessed on the basis of the EU directives. However, there is no concept of enhanced CDD measures for high risk customers, or reduced CDD measures for low risk customers. In general, customer requirements are implemented in Norway, but the full range of CDD requirements under the FATF are not.
The 2005 FATF report further finds that Norway is non-compliant with Recommendation 6 regarding politically exposed persons and correspondent banking, as it has not implemented the FATF measures for establishing relationships under both categories. Norway, however, is fully compliant with the FATF recommendations regarding new technologies and non face-to-face business. The 2005 FATF report observes that Norway is fully compliant with Recommendation 4 regarding financial institution secrecy and confidentiality. The legal duty of confidentiality does not prohibit disclosure by reporting institutions if specifically prescribed by law, and thereby enables the exercise of the AML/CFT investigative and supervisory powers of the ØKOKRIM. The FATF recommends Norway to extend this confidentiality and disclosure arrangement to other institutions as well.
According to the 2005 FATF report, Norway is fully compliant with Recommendations 11 and 21 regarding monitoring of unusual transactions and transactions with higher risk countries. Reporting institutions were required by law to put in place electronic monitoring systems before the end of 2004. Norway has also revised its declaration system and its systems for monitoring cross-border currency transportation under the Currency Register Act, which creates a Currency Transaction Register where all declaration information are to be stored and can be accessed by the police and other investigating authorities. The FATF observes that the legal measures therein are "broadly adequate" (p. 8).
As the 2005 FATF report states, Norway is largely compliant with Recommendation 13 relating to STRs and fully compliant with Recommendation 14 on protection and no-tipping off. The 2006 ØKOKRIM annual report states that the ØKOKRIM is the body responsible for receiving, processing, and analyzing STRs in accordance with the Money Laundering Act, and reporting institutions include financial institutions (e.g. banks, securities firms and insurance companies), lawyers, estate agents, auditors, accountants, and dealers in valuable objects worth NOK 40,000 or more. The FATF also expresses its doubt on the effectiveness of STRs in Norway, since STRs are very few and further decreasing. In addition, the STR rationale is unsound and not focused on pinning down suspicious transactions. Tipping-off in connection with STR is prohibited. All other reporting covered by Recommendation 19 complies fully with the FATF requirements. With regard to Recommendation 25 relating to guidelines and feedback, the FATF finds that the ØKOKRIM does not provide adequate guidance or feedback to reporting institutions regarding STR, due partially to a paucity of resources. In a similar vein, STR guidelines to reporting institutions regarding terrorist financing (SR IV) are unclear and create doubt as to their effectiveness.
Per the 2005 FATF report, Norway is largely compliant with Recommendations 15 and 22 regarding internal controls, compliance, audit, and foreign branches. Norway does have certain internal control and audit requirements for reporting institutions, but they do not measure up to the FATF recommendations, and their implementation is deficient. Reporting institutions do not show evidence of voluntarily applying the higher FATF standards. As for foreign branches of Norwegian institutions, they are required by Norwegian law to observe FATF recommended AML/CFT measures as far as the host country's laws permit; however non-observance due to prohibition by host country laws is not required to be notified to the FSAN. The 2005 FATF report further observes that Norway is partially compliant with Recommendation 18 regarding shell banks. The FATF finds that reporting institutions are not prohibited from establishing and maintaining correspondent banking relationships with shell banks; nor are they required to "satisfy themselves that a respondent financing institution in a foreign country is not permitting its accounts to be used by shell banks" (p. 143).
Per the 2005 FATF report, Norway is largely compliant with Recommendations 17, 23 and 29 regarding the supervisory and oversight system and sanctions; and partially compliant with Recommendations 25, 30, and 32 regarding guidelines and feedback, resources, integrity, training, and statistics. The FSAN is the financial supervisory authority in Norway and shares the licensing of institutions with the Ministry of Finance. Its prudential supervision role includes AML/CFT supervision, and it has a broad range of sanctions for non-compliance. For example, breaches of AML/CFT compliance have prompted sanctions in the form of letters requesting corrective action. However, its AML/CFT-related off-site and on-site supervision is irregular and limited in scope, leaving the system vulnerable to major risks. Guidance and feedback, resources, training and statistics, as previously mentioned, are insufficient. As the 2005 FATF report finds, Norway is partially compliant with SR VI regarding MVTS. Supervision and sanction as well as reporting in this sector appear not very effective, and there has been an instance of a breakdown in communication between the MLT and an MVTS provider.
3. Preventive Measures - Designated non-Financial Business and Professions
According to the 2005 FATF report, Norway is partially compliant with Recommendation 12 regarding the CDD and record-keeping requirements of the Designated non-Financial Business and Professions (DNFBPs). The DNFBPs subject to AML/CFT obligations in Norway include real estate agents, dealers in precious metals or stones dealing in Norwegian krone (NOK) 40,000 or more, lawyers and other independent legal professionals, auditors, and accountants. Their CDD obligations are similar to those of financial institutions, and hence suffer from the same deficiencies of those institutions. In general, their customer requirements are implemented, but the full range of CDD requirements are not. Further, dealers in precious stones and metals are not supervised on their AML/CFT compliance and are not subject to administrative sanctions. Concerns have also been voiced by the FATF about the scope of application of the AML/CFT requirements on company service providers.
The 2005 FATF report finds that Norway is largely compliant with Recommendation 16 regarding STRs. Further, the FATF observes that the DNFBPs have "satisfactorily implemented record keeping requirements" (p. 10). Their internal controls and communication routines also meet FATF requirements. But the FATF expresses concerns about the effectiveness of both, and calls for clearer and more sector-specific AML/CFT guidelines. The FATF notes that Norway is in the process of addressing this recommendation for lawyers and accountants/auditors. The 2005 FATF report states that Norway is largely compliant with Recommendation 24 regarding regulation, supervision, and monitoring of DNFBPs, and partially compliant with Recommendation 25 relating to guidelines and feedback. The FSAN supervises the DNFBPs, issues ad hoc guidance and applies administrative sanctions; however, its resources are too limited to ensure effective supervision. Further, dealers in precious stones and metals are not supervised on their AML/CFT compliance, and are not subject to administrative sanctions. The FATF recommends that Norway assign an agency to supervise this sector. Norway is fully compliant with Recommendation 20 regarding other non-financial businesses and professions.
4. Legal Person and Arrangements & Non-Profit Organizations
According to the 2005 FATF report, Norway is largely compliant with Recommendation 33 regarding legal persons and beneficial ownership. Registered information for legal persons is mandatory, up-to-date, and easily retrievable in Norway. However, the FATF recommends that Norway make information on beneficial ownership more easily accessible and in a timely manner. Per the 2005 FATF report, Recommendation 34 pertaining to legal arrangements - beneficial ownership and control information - is not applicable to the Norwegian context, since "Norwegian law does not recognise the legal concept of a trust, including trusts created in other countries" (p. 123). Further the report states that "there are no other legal arrangements that are of a similar nature to a trust, or which would otherwise meet the definition of a "legal arrangement" as defined in the FATF Recommendations" ( p. 123). The 2005 FATF report finds that Norway is non-compliant with SR VIII regarding non-profit organizations (NPOs). This is because Norwegian laws do not require charitable organizations to register, but require the bank account holders of these organizations to be identified. This weakens monitoring, and the problem is compounded by the fact that the sector has no CFT measures, or measures for beneficial ownership. In this context, the 2005 U.S. DoS report finds that the FSAN is taking steps to bring charitable organizations under the purview of reporting requirements.
According to the 2005 FATF report, Norway is largely compliant with Recommendation 31 regarding national cooperation and partially compliant with Recommendation 32 regarding statistics. Formal meetings for cooperation occur, but they do not produce "solid outcomes" (p. 146). Also, interagency cooperation between the police, the Prosecution Authority, the MLT, customs and tax authorities, and supervisors could be further enhanced. In this context, the ØKOKRIM website reports that it cooperates with other police units and surveillance authorities to combat economic crime, provides investigative assistance to the police districts within Norway, and helps them in enhancing their expertise, through formations of interdisciplinary investigative teams. The 2005 FATF report further observes that statistics collection with regard to mutual legal assistance and extradition is either nonexistent, unavailable, or inadequate.
Per the 2005 FATF report, Norway is largely compliant with Recommendation 35 pertaining to conventions and partially compliant with SR I relating to UN Special Resolutions. With a few exceptions in reference to self-laundering and beneficial ownership, Norway has fully implemented the Vienna, Palermo and Terrorist Financing Conventions. As for the UNSCR S/RES/1267(1999) and the UNSCR S/RES/1373(2001), Norway has inadequately implemented them and does not monitor their compliance effectively.
As noted by the 2005 FATF report, Norway is largely compliant with Recommendations 36 and 37, and SR V regarding mutual legal assistance (MLA). MLA applies to both money laundering and terrorist financing, and applies dual criminality. The Extradition Act has provisions for MLA, and Norway has also signed agreements with other Nordic countries (Denmark, Finland, Iceland, Norway, and Sweden), Schengen countries (Austria, Belgium, Denmark, Finland, France, Germany, Greece, Iceland, Italy, Luxembourg, Netherlands, Norway, Portugal, Spain, and Sweden), and the EU for MLA. However, problems arise when MLA is warranted in areas that are not adequately criminalized in Norway, such as self-laundering, money laundering by only two individuals, and funds collection for a terrorist or terrorist organization. Further, Norway does not collect statistics for MLA requests and applications.
The 2005 FATF report further finds that Norway largely complies with Recommendations 37 and 39 and SR V regarding extradition. Both money laundering and terrorist financing are extraditable offences. The Nordic Extradition Act regulates extradition to Nordic countries and the Extradition Act regulates extradition to other countries. Norwegian nationals may not be extradited (except to Nordic countries). However, as the FATF notes, problems arise when extradition is warranted in areas that are not adequately criminalized in Norway, such as self-laundering, money laundering by only two individuals, and fund collection for a terrorist or terrorist organization.
According to the 2005 FATF report, Norway is fully compliant with Recommendation 40 regarding other forms of international cooperation. Norway has signed a number of international agreements and participates in working groups created to facilitate financial sector co-operation within the EU. The MLT also has the power to share information with other FIUs without a Memorandum of Understanding (MoU). It has, however, per the 2007 IMF report on "Financial Integration in the Nordic-Baltic Region: Challenges for Financial Policies," signed bilateral MoUs with the Baltic-Nordic supervisors, with provisions for AML/CFT cooperation. The MLT, as the 2005 FATF report finds, has designated staff to act on foreign requests for information, though the system has not been tested for efficacy. The 2006 ØKOKRIM Annual report also states that it participates in the FATF, the Egmont Group, and the Interpol working group to combat money laundering and terrorist financing. The ØKOKRIM, per its website, is a part of the Money Laundering Expert Group, a subgroup within the Baltic Sea Task Force on Organized Crime that has the Nordic-Baltic states, Russia, Poland and Germany as members. The 2005 U.S. DoS report adds that Norway collaborates with the Europol and is a party to the Council of Europe Convention on Laundering, Search, Seizure, and Confiscation of the Proceeds from Crime. It has also ratified all twelve of the International Conventions and Protocols relating to terrorism.
Financial Action Task Force (FATF), "Third Mutual Evaluation/Detailed Assessment Report on Anti-Money Laundering and Combating the Financing of Terrorism: Norway," June 2005. Available from Financial Action Task Force website. Accessed on November 2, 2007. (FATF 2005)
International Monetary Fund, "Norway: Report on the Observance of Standards and Codes - FATF Recommendations for Anti-Money Laundering and Combating the Financing of Terrorism," Country Report No. 05/423, Washington D.C.: IMF, December 2005. Available from International Monetary Fund website. Accessed on November 2, 2007. (IMF 2005)
National Authority for Investigation and Prosecution of Economic and Environmental Crime - Den sentrale enhet for etterforskning og påtale av økonomisk kriminalitet og miljøkriminalitet (ØKOKRIM)
European Union Directive on the Prevention of the Use of the Financial System for the Purpose of Money Laundering and Terrorist Financing No. 2005/60/EC, 2005 (Third EU Money Laundering Directive)
International Monetary Fund, "Financial Integration in the Nordic-Baltic Region: Challenges for Financial Policies," October 2007. Available from International Monetary Fund website. Accessed on November 2, 2007. (IMF 2007)
ØKOKRIM, "General Information about ØKOKRIM," Oslo, Norway: ØKOKRIM, November 2005. Available from ØKOKRIM website. Accessed on November 2, 2007. (ØKOKRIM 2005)
U.S. Department of State, Bureau for International Narcotics and Law Enforcement Affairs, "International Narcotics Control Strategy Report 2005," March 2005. Available from U.S. Department of State website. Accessed on November 16, 2007. (U.S. DoS 2005)
Norway