In September, the Eastern and Southern African AML Group (ESAAMLG), the regional FATF-style body, published a mutual evaluation report (MER) on Madagascar.  This starts by saying that Madagascar is facing significant money laundering risks related to the importance of certain underlying offences (corruption, tax and customs offences) as well as the natural (natural resource trafficking) and geographical (drug trafficking) characteristics of the island.  It is also said to have problems because of judicial corruption; the weakness of state institutions, especially after the 2009 political crisis, and the largely informal nature of the economy and the low banking penetration rate.  It does not yet have a national AML/CFT national policy based on a national risk assessment, and implementing one is one of several priority actions recommended by the report.






Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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