10 YEARS FEDERAL FINANCIAL MONITORING SERVICE

Transcription

1 10 YEARS FEDERAL FINANCIAL MONITORING SERVICE Аnnual Report 2011

2 FEDERAL FINANCIAL MONITORING SERVICE ROSFINMONITORING ANNUAL REPORT 2011 MOSCOW 2012

3 FEDERAL FINANCIAL MONITORING SERVICE... during all these years due to the high professionalism and responsibility of Rosfinmonitoring s employees an efficient system of countering laundering of dirty money and terrorist financing has been established in Russia... (from congratulatory speech by Vladimir Putin, at the Rosfinmonitoring s 10th anniversary) ANNUAL REPORT 2011 Page 1

4 DEAR READERS! This is the Annual Report outlining the results of the activities carried out by the Federal Financial Monitoring Service in its anniversary year of For the past decade we have managed to accomplish much. Based on the international legal system a national legislative framework has been elaborated having enshrined the global standards in the anti-money laundering and terrorist financing (AML/CFT) sphere, the AML mechanisms subject to the Russian peculiarities have been outlined, and the national AML system has been established virtually from scratch. As a result Russia not only managed to quit the black list where it was initially included by the global community, but to join the states having the most authoritative AML services. Last year jointly with the public authorities and private sector Rosfinmonitoring kept on enhancing the Russian national AML/CFT system. Using the risk-based approach at all stages of its activities and continued assessment of the Russian AML system, Rosfinmonitoring managed to timely reveal and promptly react to the existing and emerging threats. Rosfinmonitoring s work logically resulted not only in positive dynamics of its performance indicators, but also in its high appraisal voiced by the Russian Government Chairman Vladimir Putin at the events dedicated to the 10 th anniversary of the Federal Financial Monitoring Service. Rosfinmonitoring s growing authority at the international arena has been confirmed by the successful adoption of the progress report on the development of the Russian national AML/ CFT system at the Financial Action Task Force (FATF) Plenary Meetings, election of the Rosfinmonitoring Head as Chairman of the Eurasian Group on Combating Money Laundering and Terrorist Financing (EAG) in November 2011, as well as decision to hold the jubilee 20 th Plenary Meeting of the Egmont Group hosted by Rosfinmonitoring in St.-Petersburg in the summer of 2012.

5 FEDERAL FINANCIAL MONITORING SERVICE The supervisory department has substantially improved its work, our activity in countering terrorist financing has immensely grown, one can also note a higher quality of the financial investigations. All the above-said is confirmed by the Report below, outlining the main results of the activities of the Federal Financial Monitoring Service in 2011 and dynamics of the key performance indicators within the framework of the national AML/CFT system. Head of Rosfinmonitoring Yury Chikhanchin ANNUAL REPORT 2011 Page 3

6 REGULATORY FRAMEWORK Efficient AML/CFT system needs an adequate legal and institutional basis, and the task of the authorized agency as a coordinator of all federal executive bodies consists in ensuring formation, effective functioning and development of that system. Rosfinmonitoring is constantly working on adapting legislation in place aimed at improvement of the Russian AML/CFT system to requirements of the global community based on new standards, and also new challenges and threats. In 2011, the main changes in the regulatory legal framework were linked to adoption of federal laws No.162-FZ On Amendments to Certain Legal Acts of the Russian Federation in Connection with Adoption of the Federal Law On the National Payment System and No.308-FZ On Amendments to the Federal Law On Combating Money Laundering and Terrorist Financing, and the Code of Administrative Offences of the Russian Federation. Those acts were developed and adopted in order to ensure maximal correspondence of the Russian AML/CFT system to the FATF requirements subject to the expertise and demands of the law enforcement practice. Federal Law No.162-FZ dated June 27, 2011 set up a mechanism of unlimited freezing of terrorist assets by court decision upon Rosfinmonitoring s application, and also extended to 30 days the period of suspension by Rosfinmonitoring of operations with monetary funds or other assets potentially related to terrorist financing. Federal Law No.308-FZ dated November 8, 2011 canceled the procedure of mandatory approval of internal control rules by a supervisory authority or Rosfinmonitoring while keeping requirements for their adoption, optimized procedure of application of administrative responsibility measures for infringements in the AML/CFT sphere, gave more detailed description of Rosfinmonitoring s power to request additional data from financial institutions on their customers transactions. Page 4

7 FEDERAL FINANCIAL MONITORING SERVICE Besides, Rosfinmonitoring took part in elaborating a number of draft laws, aimed at the improvement of the AML/CFT system, and at the development of the financial sector of the economy and consolidation of the economic component of the national security. Thereupon it is necessary to mention Federal Laws No.161- FZ dated June 27, 2011 On the National Payment System and No.3-FZ dated February 1, 2012 On Accession of the Russian Federation to the Convention on Combating Bribery of Foreign Public Officialls in International Business Transactions. ANNUAL REPORT 2011 Page 5

8 IT SUPPORT Successful tackling of the AML/CFT-related challenges by Rosfinmonitoring depends to a large extent on the level of IT support to collecting and processing information submitted by the subjects of primary financial monitoring under the current legislation. Successful functioning of IT system ensured for Rosfinmonitoring a regular reception and processing of about 9 million reports on transactions with monetary funds and other assets in Number of transaction reports submitted to Rosfinmonitoring 2011 year 2010 year (mln.) Within the reported period, in order to ensure higher quality and timely delivery of information, Rosfinmonitoring : continued to supply special Workbench Organization software to non-credit institutions supporting the online informational interaction with Rosfinmonitoring. In 2011, over 2,000 Workbenches Organization software packages were provided to non-credit institutions; developed and published on its official website a software application Preparation of Transaction Reports which allows data to be filled in, verified and printed. For further efficiency of IT support of financial investigations Page 6

9 FEDERAL FINANCIAL MONITORING SERVICE and other functional activities, Rosfinmonitoring: accomplished installation of functional subsystems and components of the Uniform Information System related to revealing and analyzing money laundering and terrorist financing schemes and typologies; to macro-analysis research; to ensuring storage, automatic processing and analysis of data, as well as to comprehensive information security; worked on widening its access to external data resources of public authorities (Rosfinmonitoring obtained access to 6 internal and 48 external data resources from 10 federal executive bodies, as well as to the data of 9 external data systems). In the reported year, within the framework of implementation of Federal Law No.210-FZ dated July 27, 2010 On Organization of Provision of Public and Municipal Services, Rosfinmonitoring took regulatory and organizational measures for its future transition to provision of public services electronically; elaborated technological processes of implementation of its key tasks using the System of Interagency Electronic Interaction (SIEI). ANNUAL REPORT 2011 Page 7

10 SUPERVISORY ACTIVITY Control over Compliance with the AML/CFT Legislation by Institutions Supervised by Rosfinmonitoring In the course of 2011, the key priority of the supervisory activities carried out by Rosfinmonitoring was higher efficiency of primary financial monitoring subjects AML/CFT-related work and further implementation of the international standards including the risk-based approach. According to Federal Law No.115-FZ dated August 7, 2001 On Combating Money Laundering and Terrorist Financing the supervisory and oversight powers in the AML/CFT sphere are distributed among various agencies, which supervise the core activities of various institutions (Bank of Russia, Federal Securities Market Service (FSMS), Russian Assay Chamber, Federal Supervision Service for Communications, Information Technologies and Mass Media (Roscomnadzor)). In case those institutions do not have a supervisor, the AML/CFT supervision is performed by Rosfinmonitoring. Page 8

11 FEDERAL FINANCIAL MONITORING SERVICE Bank of Russia FSMS Roscomnadzor Credit institutions Assay Chamber Jewelry companies Professional securities market participants Management companies Insurance institutions Credit consumer cooperatives Federal postal service operators Micro-financial institutions Rosfinmonitoring Leasing companies Factoring companies Gambling entities Payment operators Pawnshops Real estate agents An important indicator of the AML/CFT system s efficient functioning is the number of institutions involved, as well as quality and quantity of reports filed by them. ANNUAL REPORT 2011 Page 9

12 As of the end of 2011, over 21,000 institutions operating in the sectors not having supervisors were registered with Rosfinmonitoring. In 2011, Rosfinmonitoring regional departments in the Federal Districts registered about 2,800 such institutions, of which about 70% were pawnshops and real estate agents (36% and 34% respectively). Institutions Registered with Rosfinmonitoring Real Estate Agents 34% Factoring Institutions 0,1% Leasing Companies 11% Gambling Sector Entities 5% Pawnshops 36% Payment operators 24% Number of institutions registered with Rosfinmonitoring in year 2010 year Page 10

13 FEDERAL FINANCIAL MONITORING SERVICE Rosfinmonitoring both directly and through its regional departments in the Federal Districts monitors compliance with the AML/CFT legislation by institutions operating in the sectors not having supervisors. Materials obtained through inspections of institutions serve as an additional source of information for financial investigations and other AML/CFT-related analytical work of the Service (about 90% of data from inspection reports on suspicious transactions were used in the course of financial investigations). Cooperation with Credit Institutions Credit institutions are the main suppliers to Rosfinmonitoring of reports on transactions with monetary funds or other assets, accounting for nearly 85% of all reports filed. Number of Reports Filed by Credit Institutions 2011 year 2010 year (mln.) It should be noted that with higher volume of transaction reports received from credit institutions in 2011, the share of suspicious transaction reports resulted from internal control remained at the level of 2010 highlighting a high degree of integration of credit institutions into the AML/CFT system. In 2011, Rosfinmonitoring acknowledged qualitative improvement in the level of its cooperation with financial monitoring ANNUAL REPORT 2011 Page 11

14 departments of banks. Following their own checks of customer activities, many banks started filing suspicious activity reports which are additional information for performing financial investigations. Besides, the number of delayed reports filed with Rosfinmonitoring nearly halved. Cooperation with Non-Credit Institutions As of the end of 2011, a total number of entities qualified as non-credit institutions amounted to about 44,000. Non-credit institutions accounted for about 15% of the total number of reports filed with Rosfinmonitoring. Compared to banks, the filing of reports by non-credit institutions with Rosfinmonitoring is not so active, which is understandable due to a significantly lower volume of transactions with monetary funds or other assets carried out by these entities. Last year the regulatory legal framework was improved, overall training for employees of non-credit institutions was held, the awareness-raising campaign (including use of the Internet) was expanded, as well as new measures to prevent inadequate compliance with the AML/CFT requirements were performed. The undertaken efforts contributed to positive trends and better results enjoyed by certain sectors. Thus, the number of reports received from non-credit institutions in 2011 grew more than 1.3-fold and amounted to about 600,000 reports. Page 12

15 FEDERAL FINANCIAL MONITORING SERVICE Number of Reports Received from Non-Credit Institutions (in thousands) 2011 year 2010 year (ths.) Interaction with Supervisory Authorities In order to strengthen the AML/CFT supervision system and to enhance efficiency of separate elements of the national AML system (financial and non-financial sectors, supervisory authorities) certain steps were taken in 2011 to establish a unified methodological and information environment to apply the riskbased approach in the supervisory activities and to raise effectiveness of inspections. Given the large number of entities operating within the supervised sectors, the supervisory efforts were focused on the entities which require enhanced attention and are the most vulnerable to ML/FT. More attention was paid to revealing and defining both zonal (typical for a federal district) and local (typical for a federal subject or a type of economic activities) risks. In 2011, the insurance companies, credit consumer cooperatives and micro-financial institutions passed under the supervision of FSMS, which will strengthen supervision over the agents of the sectors compliance with the AML/CFT legislation. ANNUAL REPORT 2011 Page 13

16 Besides, since January 2011 all supervisory authorities have been authorized to investigate and initiate proceedings on administrative offences under Article of the RF Code on Administrative Offences (CAO). In order to provide methodological assistance and achieve uniformity of approaches to administrative procedures and application of Article of CAO, Rosfinmonitoring elaborated methodological materials on conducting administrative procedures; held training workshops on this issue in all regions for territorial departments of supervisory authorities. In 2011, following earlier elaboration and coordination with supervisory authorities, there was an approbation of the package of efficiency indicators for supervisory activities in the AML/ CFT sphere, both generally and regarding different segments of financial and non-financial institutions, allowing to coordinate more precisely supervisory activities, as well as to enhance coordinative role of Rosfinmonitoring. The work on improving the Principles and approaches to formation of internal control systems of institutions was continued. Adoption of Rosfinmonitoring Order No.59 dated February 17, 2011 regulating customers and beneficiaries identification, including assessment of risks of customer s involvement in money laundering and terrorist financing, allowed to improve procedures for customers and beneficiaries identification to systematize measures taken by institutions in identifying a customer, to define measures of institutions in revealing high-risk customers etc. To provide assistance to the supervised institutions a list of signs of customer s high-risk activities and transactions (informational letter No.17, dated August 2, 2011) was developed jointly with Rosfinmonitoring s analytical departments. The outcome of this work allowed institutions to streamline identification procedures and focus on the high-risk customers timely detection. In 2011, suspicious transaction signs for micro-financial institutions, and also signs of transactions potentially aimed at Page 14

17 FEDERAL FINANCIAL MONITORING SERVICE the terrorist financing both for credit and non-credit institutions, were elaborated. RF Government decree on approval of Requirements to the Internal Control Rules Developed by Institutions in the AML/ CFT Purposes, has been drafted. The measures taken in this direction will facilitate a more precise adjustment of the internal control in the institutions and, in consequence, a higher efficiency of the AML/CFT system in whole. ANNUAL REPORT 2011 Page 15

18 FINANCIAL INVESTIGATIONS In order to address the priorities defined by the President and the Government of the Russian Federation in the AML/CFT sphere, Rosfinmonitoring in 2011 focused on conducting financial investigations on the large-scale economic crimes, detecting and preventing suspicious financial schemes and criminal financial turnover mechanisms, including corruption-related ones, and also on developing preventive and protective measures as well. In 2011, Rosfinmonitoring jointly with the law-enforcement, tax and supervisory authorities took coordinated measures in preventing schemes of funds outflow to the shady turnover. Such cooperation resulted in initiation of a number of criminal cases. Using materials of financial investigations of Rosfinmonitoring, the law-enforcement authorities held investigation and search operations in relation to customers of several dozens of commercial banks. Those operations resulted in about 50 criminal cases initiated for illegal acts on the part of owners and customers of banks, a number of banks had their licenses revoked. A joint financial investigation by Rosfinmonitoring, FSMS and law enforcement agencies resulted in suppression of a largescale scheme of money transfer abroad (tens of billion Rubles) through accounts of a large number of companies with fictitious signs. In 2011, Rosfinmonitoring focused considerably on countering money laundering from corruption. In this regard, Rosfinmonitoring jointly with the law-enforcement authorities concentrated its efforts on detecting and preventing corruption-generating mechanisms, and elaborating supervisory, preventive and protective measures in the public sector. Besides, in 2011, in order to ensure transparency of financial and economic activities of state corporations and other financial institutions with public share, Rosfinmonitoring revealed facts of founding entities affiliated with banks for carrying out suspi- Page 16

19 FEDERAL FINANCIAL MONITORING SERVICE cious transactions and providing shady financial services. Jointly with the law enforcement authorities, Rosfinmonitoring worked to counter elaboration of illegal schemes, as follows: in the use of public funds for implementation of state support programs for small and medium businesses, unprotected and low-income groups of population; in the sphere of public procurement of goods, execution of work and rendering of services for state and municipal needs, in defense industry, in the housing and communal services. In 2011, Rosfinmonitoring conducted nearly 1,500 financial investigations in relation to persons suspected of committing crimes of the said category. About one tenth of materials of financial investigations with signs of corruption proceeds laundering were disseminated to the law enforcement authorities. Most financial investigations conducted by Rosfinmonitoring in 2011 were carried out in reply to requests from the Russian law enforcement authorities. Rosfinmonitoring continued to cooperate particularly closely with the Ministry of Internal Affairs (MIA), Federal Security Service (FSS) and Federal Drug Control Service (FDCS). Besides, Rosfinmonitoring conducted financial investigations based on requests from other executive bodies, as well as statements and requests from citizens and organizations. ANNUAL REPORT 2011 Page 17

20 Distribution of checks in reply to requests and statements in 2011 Requests from law enforcement Requests from other executive agencies Requests from FIUs Rrequests and applications from citizens and organizations In 2011, most crimes categorized under Articles 174 and of the RF Criminal Code (CC), were revealed in the credit & financial sphere nearly 300. Fraud (CC Art.159), trafficking in drugs, psychotropic substances or their analogs, dangerous substances (CC Arts.228, 228-1, 229, 232) remain among the most common predicate offences. Positive dynamics of financial investigations (both spontaneous and in reply to the law enforcement requests) and demand for their outcomes are illustrated by over 20% increase in quantity of completed financial investigation materials which contain data on subjects reasonably suspected of money laundering disseminated to the law enforcement authorities. Page 18

21 FEDERAL FINANCIAL MONITORING SERVICE Number of completed financial investigation materials disseminated to law enforcement authorities 2011 year 2010 year As to the international financial investigations, there was 1.5-fold increase in the number of primary checks based upon requests from foreign financial intelligence units (FIUs). Approximately 70% of requests from foreign FIUs led to international financial investigations. ANNUAL REPORT 2011 Page 19

22 Ratio of checks in reply to FIU requests and international financial investigations 2011 year Checks in reply to FIU requests 2010 year International financial investigations conducted Foreign FIUs duly disseminated to the foreign law enforcement authorities over 170 international financial investigation materials provided by Rosfinmonitoring. In 2011, with participation of Rosfinmonitoring and based upon its materials disseminated to the law enforcement authorities, over 1,300 criminal cases were initiated, about 150 of which were initiated on money laundering Articles. About 350 criminal cases referring to the data and materials provided by Rosfinmonitoring, were sent to courts, in approximately 100 cases defendants actions were categorized under the money laundering Articles. The courts passed about 200 convictions with about 30 of them in relation to money laundering. In 2011, financial investigations by Rosfinmonitoring were outlined by the following trends: convictions on large-scale and complex cases were considered as priority in that work; the augmentation of a legalized large-scale income to over Page 20

23 FEDERAL FINANCIAL MONITORING SERVICE 6 million Rubles, which considerably reduced the number of revealed money laundering crimes, particularly in economically under-developed regions; new entry into CC (Art ) requiring availability of a purpose to legalize assets, obtained by a person through commission of crime, which led to revision of the relevant law enforcement practice. ANNUAL REPORT 2011 Page 21

24 COMBATING FINANCING OF TERRORISM Within the framework of countering terrorist financing, Rosfinmonitoring plays an important role in timely detecting possible channels and sources of terrorist and extremist financing. The AML/CFT work carried out in 2011 led to higher levels of interagency cooperation between Rosfinmonitoring and the law enforcement authorities in the CFT area, resulting in better primary data processing. Compared with 2010, the number of requests received by Rosfinmonitoring from the law enforcement authorities increased by about 35%, with their considerably higher quality. CFT-related requests from law enforcement authorities 2011 year 2010 year The number of CFT-related financial investigations increased by over 30%. In 2011, over 3,000 financial investigations were conducted, with 450 of them being primary ones. About 2,500 materials were disseminated to the law enforcement authorities for an operational check. Page 22

25 FEDERAL FINANCIAL MONITORING SERVICE CFT-related financial investigations 2011 year 2010 year One of the key components of the CFT system remains compilation of the List of Organizations and Individuals Reported for Involvement in Extremist Activities or Terrorism ( List ), bringing the List to the notice of institutions carrying out transactions with monetary funds or other assets, as well as suspension of transactions involving subjects of the List. These efforts are aimed at the implementation of international commitments of the Russian Federation regarding blocking of international terrorist financing channels, and also serve as a certain barrier on the way of using legal channels for money transfers by the designated individuals and entities, as well as to detect kindred or other relationships in carrying out transactions by terrorists. In conformity with the amendments to the AML/CFT legislation which entered into force in 2011 the List is now published on the Rosfinmonitoring official website, as well as in the Rossiyskaya Gazeta ( Russian Gazette ); the List now includes persons involved into both terrorist and extremist activities. In 2011, seven versions of the List were published and brought to the notice of the institutions carrying out transactions with monetary funds or other assets. ANNUAL REPORT 2011 Page 23

26 40 th version of the List of Organizations and Individuals Reported for Involvement in Extremist Activities or Terrorism Russian list International list The 40 th version of the List dated December 14, 2011 includes: (International Section) entities and 394 individuals (in conformity with the UN Security Council Resolutions), (National Section) - 48 terrorist and extremist organizations, whose activity on the Russian territory is prohibited by decision of the RF Supreme Court and in relation of which there are court rulings on their liquidation or prohibition of their activities, and 2,382 individuals, in relation of which criminal cases (as per Articles of CC on extremist and terrorist issues) were initiated, or convictions were delivered and entered into force, for committing the above crimes. 31 individuals (in conformity with the UN Security Council Resolutions), 2 organizations whose activity on the Russian territory had earlier been prohibited by decision of the RF Supreme Court, as well as 438 individuals due to termination of prosecution under relevant Articles of CC and cancelation or revocation of conviction were delisted. During 2011, upon daily monitoring of reports involving subjects of the List, Rosfinmonitoring suspended 10 transactions, and forwarded data thereof to the public prosecutor s and law enforcement authorities concerned. Simultaneously the subjects of the List were scrutinized for detecting and analyzing their environment (relations). Another important sector of activities in the reported year Page 24

27 FEDERAL FINANCIAL MONITORING SERVICE was implementation of the international commitments of the Russian Federation within the FATF Recommendations. in relation to the check of non-profit organizations as the most vulnerable to the risk of their usage for the financing of terrorism purposes; trans-border and internal transportation of cash by individual cash couriers, including through usage of different payment systems. Taking into account importance of these sectors, Rosfinmonitoring, jointly with the law enforcement and executive authorities, and ministries concerned adjusted measures in organizing complex inspections and checks. ANNUAL REPORT 2011 Page 25

28 INTERNATIONAL COOPERATION In 2011, international activities of Rosfinmonitoring focused on three main areas contributing to further development of the national AML/CFT system and its higher efficiency: cooperation with international organizations in the AML/ CFT sphere; bilateral cooperation with foreign FIUs; support in EAG secretariat work and participation of Russia in the Group s activities. Rosfinmonitoring headed Russian delegations at such key AML/CFT international forums as FATF, MONEYVAL, EAG, APG, Egmont Group. For the purpose of strengthening the international standing of the country, Rosfinmonitoring jointly with the concerned government authorities took part in developing Russia s concerted position at the venues of the FATF and FATF-style regional bodies. The successful adoption of the progress reports in the FATF and MONEYVAL in June and September 2011 respectfully, confirmed high level of interagency cooperation and recognition of Russia s efforts aimed at improving its national legislation. Rosfinmonitoring experts involvement into revision of the international AML/CFT standards and FATF mandate was aimed at considering Russian specifics in those documents, for Russia s national interests to be taken into account. In 2011, Rosfinmonitoring directed its efforts on strengthening Russian positions in the principal international and regional organizations. Mr. Yury Chikhanchin, the Rosfinmonitoring Head was elected as the EAG Chairman, and Mr. Vladimir Nechaev, Assistant to the Russian Government First Deputy Chairman as the MONEYVAL Chairman. Besides, Russian representatives were sent on mission to work at the FATF and MONEYVAL secretariats. Among the priorities of international cooperation were measures intended to ensuring consolidating role of Russia and Rosfinmonitoring in developing regional AML/CFT system Page 26

29 FEDERAL FINANCIAL MONITORING SERVICE throughout Eurasia, and to enhance cooperation between the EAG and other international bodies within the framework of joint projects. The signing in 2011 of the Agreement on Reorganization of the EAG as an Intergovernmental Organization helped to further promote its status and activate work of all its members. Taking into account the APEC summit in the Russia s Far East pending in 2012, special attention was paid to Russia s participation in the APG events as an observer. The central vector of Rosfinmonitoring activity within the framework of the Egmont Group was preparation of its jubilee 20 th plenary meeting with expected participation of over 100 foreign FIUs (July 2012, Russia, St.-Petersburg). In 2011, under the sponsorship of Rosfinmonitoring, FIUs of Azerbaijan, Kazakhstan and Uzbekistan were admitted to the Egmont Group, FIUs of Tajikistan and Turkmenistan were further promoted as candidates for the Egmont membership in the nearest future. Cooperation between Rosfinmonitoring and foreign FIUs is based on bilateral and multilateral agreements, as well as the Egmont Group principles. In 2011, the list of foreign FIUs with whom Rosfinmonitoring has interagency AML/CFT interaction widened: agreements were signed with FIUs of Turkmenistan, Bahamas, British Virgin Islands and Mongolia. As of the end of 2011, Rosfinmonitoring had 56 interagency agreements signed, and 40 more were under development. Data exchange with foreign FIUs is an important function of Rosfinmonitoring. The most active correspondence was held with FIUs of France, Estonia, Ukraine, Croatia, Cyprus, Belgium, UK, Czech Republic, Belarus, Luxembourg, Montenegro, Slovakia and USA. Against the background of substantial growth of volumes of data exchanged via the Egmont Secure Web, there were higher quality and speed of processing of requests for information sent to foreign FIUs and received from them. As a result, Rosfinmonitoring conducted over 500 interna- ANNUAL REPORT 2011 Page 27