Countries/Jurisdictions of Primary Concern - Qatar
Qatar has become an increasingly important banking and financial services center in the Gulf region. Despite the growth of the banking sector and increasing options for financial services, Qatar still has a largely cash economy. The expansion of the financial and trade sectors, the large number of expatriate laborers who send remittances to their home countries, the liberalization and growth in the real estate sector, uneven corporate oversight, and Iran’s efforts to bypass sanctions through Gulf economies make Qatar increasingly vulnerable to the threat of money laundering. Exploitation of charitable services by terrorism financiers continues to be a concern, as does the misuse of exchange houses and other non-bank financial systems. In 2013, the Qatar State Security Bureau established a Directorate of Economic Affairs to combat burgeoning economic crimes and public corruption.
For additional information focusing on terrorist financing, please refer to the Department of State’s Country Reports on Terrorism, which can be found at: http://www.state.gov/j/ct/rls/crt/
DO FINANCIAL INSTITUTIONS ENGAGE IN CURRENCY TRANSACTIONS RELATED TO INTERNATIONAL NARCOTICS TRAFFICKING THAT INCLUDE SIGNIFICANT AMOUNTS OF US CURRENCY; CURRENCY DERIVED FROM ILLEGAL SALES IN THE U.S.; OR ILLEGAL DRUG SALES THAT OTHERWISE SIGNIFICANTLY AFFECT THE U.S.: NO
CRIMINALIZATION OF MONEY LAUNDERING:
“All serious crimes” approach or “list” approach to predicate crimes: List approach
Are legal persons covered: criminally: YES civilly: NO
KNOW-YOUR-CUSTOMER (KYC) RULES:
Enhanced due diligence procedures for PEPs: Foreign: YES Domestic: NO
KYC covered entities: Banks, real estate brokers, dealers of precious metals or stones, lawyers and notaries, trust funds and company service providers, and non-profit organizations (NPOs)
Number of STRs received and time frame: 384 in 2013
Number of CTRs received and time frame: Not applicable
STR covered entities: Banks, real estate brokers, dealers of precious metals or stones, lawyers and notaries, trust funds and company service providers, and NPOs
MONEY LAUNDERING CRIMINAL PROSECUTIONS/CONVICTIONS:
Prosecutions: 1 in 2013
Convictions: 0 in 2013
RECORDS EXCHANGE MECHANISM:
With U.S.: MLAT: NO Other mechanism: YES
With other governments/jurisdictions: YES
Qatar is a member of the Middle East & North Africa Financial Action Task Force (MENAFATF), a FATF-style regional body. Its most recent mutual evaluation can be found at: http://www.menafatf.org/images/UploadFiles/QatarMER1.pdf
ENFORCEMENT AND IMPLEMENTATION ISSUES AND COMMENTS:
The Government of Qatar did not pass or implement any new legislation in 2013 pertaining to its AML/CFT regime; a law on charities oversight was in development throughout the year, but remained in draft status as of December 31. The National Anti-Money Laundering and Terrorism Financing Committee (NAMLC) continues to be the government agency charged with AML/CFT policy. It is under the direction of the Deputy Central Bank Governor.
The Qatar Financial Information Unit (QFIU) issued guidelines on suspicious transaction reporting (STR) obligations and conducted outreach and workshops with financial institutions. In 2012, the QFIU launched its “2013-2017 Strategy: Financial Transparency to Promote Stability and Security.” In 2013, the QFIU began implementing eight strategic goals as part of this five-year initiative, focusing on building administrative capacity, technical capacity, promoting QFIU cooperation and coordination with other national authorities, identifying trends and indicators of money laundering and terrorism financing, promoting and monitoring the implementation of controls related to suspicious transaction reporting systems, establishing a suspicious transaction reporting system, building effective relationships with international agencies, and raising awareness of civil society institutions about the role of the QFIU.
The National Anti-Terrorism Committee (NATC), located in the Ministry of Interior, has the authority by resolution to designate as terrorists and terrorist organizations those who finance terrorism independently of lists forwarded to Qatar pursuant to UNSCRs 1276 and 1373. Qatar’s Ministry of Social Affairs and Labor monitors and licenses non-governmental charitable organizations and requires that Qatari organizations’ foreign partners submit to a vetting and licensing process before receiving Qatari funds. In the past, Qatar has revoked foreign charities’ licenses over concerns about their activities. The potential abuse of the charitable sector by terrorist financiers continues to be a concern.
The Qatari government recently established a technical team headed by the chief of the QFIU, comprised of members of the NATC, NAMLC, and the Ministry of Foreign Affairs, to coordinate with the Treasury Department on issues related to counterterrorism financing.
In 2013, the Qatar State Security Bureau established a Directorate of Economic Affairs to combat burgeoning economic crimes and potential public corruption. As of December 2013, the Public Prosecutor’s Office received one report on a money laundering crime, with no judgment issued as of the end of the year.
Qatar should continue its efforts to effectively implement AML/CFT regulations and procedures, and should ensure sufficient resources and training are provided to develop the necessary institutional capacity. Qatar should continue to work to increase the rate of investigations and prosecutions by building capacity within its law enforcement authorities. Qatar also should pursue outreach and enforcement activities to ensure terrorist financing-related STR reporting occurs, and ensure the UNSCRs 1267 and 1373 freezing regime is effectively implemented. Qatar should mandate the declaration of cross-border movements of bulk cash or negotiable instruments.
Regarding Iran-related terrorism and proliferation transactions, the Central Bank ordered financial institutions to freeze any assets of entities listed in UNSCRs 1737, 1747, 1803, and 1929 and prohibited transactions with listed entities. Bank Saderat is the only active Iranian financial entity, with two small branches in Doha. As a foreign bank, Saderat cannot open new branches or expand its activities in Qatar. Reflecting general concerns in the Gulf about Iranian financial institutions, many Qatari banks no longer clear checks for Bank Saderat, and Qatari banks have ended all correspondent relations with Saderat.