1. SAI INDIA Evaluation of Current Situation of Anti-Corruption in India P.K.Tiwari Principal Director Kulwant Singh Director O/o Comptroller and Auditor General of India New Delhi

2. NATIONAL ANTI-CORRUPTION STRATEGY AND ACTION PLANS
A draft Anti-corruption strategy has been recommended by CVC.
Chapters or contents covered in the anti-corruption document
Objectives & priority areas.
Prevention and criminalization/law- enforcement measures
Public participation/education.
Anti-corruption strategy - action plan.
Yes
Elements contained in the Anti-Corruption Action plan?
Specific measures/ institutions /time frame responsible for the implementation of each measure.
Publication of Anti-corruption Strategy

3. Contd. Openness and transparency in the operation of agencies.
Measures employed in fighting corruption?
Openness and transparency in the operation of agencies.
(b) Development & implementation of entitlements, norms & standards.
(c) Administrative reform.
(d) Development and enforcement of the code of conduct and the code of professional ethics.
(e) Penalty forms to heads of the agencies in case of occurrence of corruption.
(f) Declaration of assets and income.

4. NATIONAL ANTI-CORRUPTION AGENCY
Yes
Main responsibilities/functions of the ACA
Conduct investigations
Disseminate knowledge on anti- corruption activities.
Raise public awareness about the fight against corruption
Identify the causes of corruption and to propose to the
Research and analysis on corruption
Keep a database on the statistics
Hotline /website in order to facilitate citizens .

5. LEGAL BACKGROUND
India criminalize different types of corrupted activities?
By a Special law on Anti-corruption
Areas to enact new legislation
Abuse of position/power
Criminal breach of trust
Extortion
Influence peddling
Nepotism
Types of measures against corruption .(most to least)
Preventive policies and measures
Detective actions (prosecutions, investigations, audits etc.)
Punitive measure (Implementing criminal and disciplinary sanctions etc.) 
Laws and regulations governing the financing of political parties.
No.

6. Contd…
laws and regulations governing code of ethics of public officials?
Yes
laws and regulations governing declaration of assets by public officials.
“accounting and auditing standards” for both public and private sectors.
yes
Legal obligation for public officials to report corruption-related offence? No
Rate the implementation of the rules/regulation in combating corruptions
Good

7. International Co- operation
Ratification of United Nations Convention against Corruption (UNCAC)
Yes
UNCAC peer review
Anti-corruption conventions, initiatives or international project
ADB-DECD Anti Corruptions Initiative for Asia Pacific.
OECD Anti Bribery Working group (Observer)
Brazil, Russia, India, China, South Africa (BRICS) Initiative
IBSA (India, Brazil, South Africa) Initiative
International Association of Anti Corruption Authorities (IAACA)
World Bank Corruption Hunter Alliance

8. Measure of success level of international cooperation
Contd…
Measure of success level of international cooperation

9. PROMOTING AWARENESS & OTHER MATTERS
Role of Media
Helped public to recognise the real situation of corruption.
Role of Society
Active but not effective
Comparison with past efforts.
Much higher than past years
Anti-corruption educational/training programme
Yes – Schools/public officials/general public
Result of the current fight against corruption
Have had positive impact, contributed to prevent corruption.

10. PROMOTING AWARENESS & OTHER MATTERS
Factors which inhibit the result of the fight against corruption.
Corrupt people are not severely punished
The collusion between law enforcers and corrupt people
Have not mobilized well people’s and media’s participation.

11. Evaluation of Current Situation of Anti-Money Laundering in India

12. LEGAL FRAMEWORK ML a criminal offence Yes
Specific laws and/or regulations covering anti-money laundering .
yes , PMLA, 2002.
Covers all money laundering aspects
Rate the implementation of anti-money laundering law
Good
Financial Intelligent Unit (FIU) functioning as national center

13. AML BOARD/AUTHORITY Official authority/board in your jurisdiction
Yes, FIU-IND & Enforcement Directorate.
Measures of AML .
(a) Report, provide and save information on great value transaction/suspicious transaction (b)Gather, treat and transform information about anti-money laundering.
AML board/authority enjoy independence.
Yes – Legal/functional/financial
Can a citizens inform AML
Yes
Updated rules and information about AML

14. AML BOARD/AUTHORITY Functions of AML/Board
Developing policies and improving legislation.
Data collecting, analyzing, evaluation.
Coordination.
Raising awareness in the public.
Carry out researches, conducting sector-based studies.
Requesting any kind of information and documents. from public institutions and organizations, natural and legal persons, and unincorporated organizations.
Exchange information and documents with counterparts in foreign countries.
Ranking of effectiveness of AML efforts.
(1 to 3)
[2] Preventive policies and measures (regulations, internal control systems, international cooperation for deterrence, raising awareness ) [2] Detective actions (prosecutions, investigations, audits etc.
[2]Punitive measure (Implementing criminal and disciplinary sanctions etc.)

15. FINANCIAL INSTITUTIONS
AML board/authority require AML & KYC procedures
Yes
Legal obligations of AML.
Internal controls and procedures to comply with regulatory framework.
Thorough client identification.
Having an anti-money laundering officer.
Client due diligence procedures.
Risk focused assessment of customer base and their transactions.
Creating and regularly updating a list of red flags concerning AML.
Prohibition of anonymous accounts.
Employee training programs regarding AML.
Independent audit/compliance function.
Identification and reporting of suspicious activities to the appropriate authorities.
Monitoring program for suspicious or unusual activities.
Policies covering relationships with politically exposed persons consistent with industry best practices.
Policy prohibiting accounts/relationships with shell banks.
Policy of protecting employees who report any suspicious transactions.

16. CONTD…
Are financial institutions obliged to comply with the legal obligations or administrative policies in terms of client due diligence procedures in your country?
Implementation systems for the identification of its customer, including customer information in the case of recorded transaction, account opening, etc.
Collecting information and assessing its customer’s AML policies and practices.
Screening its customer’s information against sanction lists issued by the government or international bodies.
Are financial institutions obliged to comply with FATF recommendations in your country?
Yes

17. INTERNATIONAL COOPERATION
Rate your organization ability to cooperate and exchange financial information at international level
Very Good
Is there any cooperation agreements or protocols among the local institutions to share financial information and financial transfers and if it’s involved with money laundering?
Yes

18. EDUCATION, AWARENESS & OTHER MATTERS
The role of citizen participation in fighting money laundering
Promoting public sector transparency and accountability and citizen participation.
Complaint system/ Whistle Blower, and Denunciation: Receiving reports and complaints on money laundering from citizen.
Punishment of MLA incidents?
The penalties are appropriate
Factor inhibit the fight against ML.
None
Controlling systems are the keystone and deterrent of AML
Yes

19. CONTD… AML educational/training programs Public officials
Financial institutions.
Business associations and private companies
Any high institution(s) providing training workshops for the employees of controlling agencies about methods to detect money laundering.
Yes
Result of the current fight against-money laundering
Have had positive impact, contributed to prevent money laundering

20. Thank You.