Oct 21, 2019
The searches and seizures conducted by Vatican police at the Secretariat of State and the Financial Intelligence Authority inaugurated an institutional crisis within the Vatican. Among its other effects, this crisis could have consequences on the next round of evaluations by the international money laundering oversight body, Moneyval.
Moneyval is the body of the Council of Europe that reviews the anti-money laundering measures of the States that join the program, to which the Holy See adhered in 2011.Ever since, Moneyval has issued periodic reports on the Holy See. The reports showed that the Holy See improved its anti-money laundering system continuously. The first report was issued in 2012 and was about the general findings on the Vatican anti-money laundering system. There have been three subsequent progress reports: in 2013, 2015 and 2017. The final release of the 2017 Moneyval progress report stressed that "the Holy See should present an update on action taken to implement the Committee´s recommendations by December 2019."
According to the regular procedure applied to States that do not undergo a reinforced examination, the next Moneyval review of the Holy See should be scheduled in 2020. The 2017 report stressed that "the Holy See will be fully evaluated against the 2012 FATF Anti-Money Laundering and Counter-Terrorism Financing Recommendations and their effective implementation within MONEYVAL's ongoing 5th round of mutual evaluations". It seems things go well. Let us take a more in-depth glance at the situation.
The 2020 Moneyval review, unlike the 2012 review, will focus on the effectiveness of the anti-money laundering law. The 2017 report noted that "the overall effectiveness of the Holy See's engagement with combatting money laundering depends on the results that are achieved by the prosecution and the courts." This is a crucial point. The 2017 progress report also stressed that "the results on the law enforcement/prosecutorial/judicial side two years after the last review remain modest" (2017 Moneyval progress report on the Holy See / Vatican City State, p. 64).