AML AUTHORITIES IN GREECE CREATING NATIONAL REGISTER OF NGOs

While have been busy discussing the reluctance of the Government of the Cayman Islands to build a Public Register of beneficial owners of corporations, saying that it is waiting for other jurisdictions to follow, the recent actions of Greece show is that governments can, and do, take information public without being ordered to do so.

Greek anti-money laundering agencies have announced that they are creating a public register of non-governmental organizations (NGOs), many of whom are "charities." It will contain all NGOs active in Greece, not just those domiciled there; the program is being directed by the Deputy Prosecutor Assigned to the country's Supreme Court. Apparently, the current situation assigns NGO enforcement to the government ministry involved in the activity the NGO is engaged in, and that arrangement is not suppressing NGO participation in money laundering, human trafficking, violation of immigration laws, forgery, and aiding smugglers, and even espionage charges.

 We hope and trust that the register contains the names and addresses of all NGO officers, advisors, board of directors, the executive director, division managers, and supervisors. With that list, compliance officers can access personal identification data, including photographs, to conduct EDD of NGO officials.