مارش 5 بارت 2

The speaker welcomes non-participant members and guests back to the room. They mention that a meeting scheduled for the ad hoc search group for the WGV chair has been canceled. The speaker then introduces the Luxembourg phase 4 report, thanking Catherine Marte for her work on it. They mention that the report will be presented in both French and English, but the translations may not always be smooth. The speaker asks the lead examiners from Switzerland and Italy to present their findings. The first examiner discusses positive developments in Luxembourg since the phase 3 report, but also highlights concerns regarding the enforcement of foreign bribery offenses and the detection of corruption. They commend Luxembourg's efforts in fighting money laundering but recommend giving more resources to the Financial Intelligence Unit. The second examiner discusses the implementation of the foreign bribery offense and other related infractions in Luxembourg. They congratulate Luxembourg on obtainin I welcome our non-participant members and other guests, who are back in the room for this afternoon. Just before we start, I have a note on the agenda. I cannot see him now, but Lorenzo asked that, for those of you in the ad hoc search group for the WGV chair, you will see on the agenda tomorrow that there is supposed to be a meeting at 8.30. For those of you on that group and who enjoy their sleep, I am very happy to say that we are not having that meeting. We have decided that it is not necessary, given the discussions that we had online fairly recently. Please do not turn up early at 8.30 and then be disappointed. Oh, sorry, there Lorenzo is. I was so confused. Yes, the meeting is off. Hopefully, that is good news for everyone. This afternoon, we are doing the first reading of the Luxembourg phase 4 report. I will give a couple of pieces of introduction first. You will see on the front sheet of the report that Catherine Marte did a lot of work on this one in the lead examiner. She also did a tremendous amount of work on the Saudi Arabia mission, and the work we will be speaking about on Thursday. She is just absent for a little while because of quite serious personal family issues, so we are sending her our best wishes. I just wanted to say that we are really, really grateful for a lot of work she has done under difficult circumstances on two major parts of this week's agenda. When we do see her back, we want to make sure that our thoughts and best wishes are passed on to her as well. The second thing is this and the French updates tomorrow are bilingual. The primary report is in French, so headsets at the ready as the updates will be done there. We are going to have two different reports on the screen. Apologies, I do not speak French, so the screen in front of me is going to be in English. I believe the screens behind me are going to be in French. Is that right? We are going to try and update them both in real time, so we are going to have to be a little bit patient with the changes that we ask as they are both going to be done. I am going to be focusing clearly on the English one, but the thing to recognise is that the translations do not always work smoothly. I have already had a few comments with the secretary where I thought, what do you mean by this? What do you mean by that? Pretty much all of them were just due to the translations. If you have comments from the English version, it may be that the French version is perfectly fine. We just either need to tweak the English version to make it make sense, or we might just have to accept that the French version has primacy in this circumstance. I am also told by the—I have been asked for the purposes of the translators, especially in the presentations at the beginning to speak slowly. This is very much on me as well, because I know I am not always the slowest speaker. I will do my best to be slow and clear and hope that the translators and the drafters can keep up with us. With that in mind, I do not know which of the lead examiners is going first. We have got Switzerland and Italy. Lorenzo, would you like to take the floor? Thank you very much, Chris. Thank you very much. Firstly, I wanted that this was a seniority before authority that made me take the floor first. By that same token, I have the privilege to be the first one to warmly thank the authorities from Luxembourg. Thank you for your commitment. Thank you for your active, very active participation, namely during the on-site visit. I also wanted to thank Ms. Barbara Uylaki, who is the new head of delegation for Luxembourg. I wanted to also thank Patrick Till. We have known him for a while. I also wanted to thank Cindy Coutinho. I wanted to second what Chris said about Catherine Marty's work. We are extremely thankful and all our thoughts go to her in this difficult moment that she is going through. The on-site visit was conducted from the 1st of May to the 5th of May last year. We were able to meet the relevant public authorities, namely law enforcement authorities, parliamentarians, but also representatives from the media, the civil society and the private sector. There have been many positive developments that we welcome since the phase 3 report that happened in 2011. Now, there are still sources for concern. There have been important legislative and institutional changes since the phase 3 report, considerable progress. However, this is all made fragile because of structural issues and resource issues that affect the whole of the criminal justice chain. One could describe the enforcement of foreign bribery offence as very weak, especially when it comes to the sentences, which we are going to look at. This is still a source of concern for the group. When it comes to the detection and the reporting of foreign bribery, a new ambitious law was adopted on 16 May 2023. I believe that the parliament actually adopted the law on the 3rd of May. We were truly there in the heart of that moment and we were able to personally welcome the adoption of the law. We met with parliamentarians at the time. This law is on the protection of whistleblowers. This is a very sensitive issue in Luxembourg, but not only in Luxembourg. This is also a sensitive issue in other countries. This law draws extensively on international standards and I think that we can particularly welcome the European Union directive because this did encourage Luxembourg and other countries to adopt a legislation that is up to the standards. Now, we believe that it is important for Luxembourg to continue to undertake concrete measures when it comes to awareness-raising in order to truly implement these new legal obligations in order to make this progress sustainable over time. Our team was also happy with the strengthening of the legislative and institutional framework for the fight against money laundering. We noted with satisfaction that there were many initiatives that were deployed by Luxembourg in order to raise awareness among authorities and the private sector to prevent money laundering. We witnessed important efforts and I think the FATF evaluation and assessment also played a role, but from the money laundering side, we truly could bear witness to the efforts that were deployed by Luxembourg. However, that being said, we can but notice that the attention that is given to detecting foreign bribery and to the laundering predicated on foreign bribery is insufficient. From an institutional point of view, we commend the pivotal role of the FIU. The FIU is at the heart of the legal regime to fight against the money laundering. However, we recommend that Luxembourg give it the appropriate capacity and resources. We have seen this. It is quite surprising for a country that has the economy that Luxembourg has, but of course other factors affect us and they were explained to us and we will be able to discuss them during the deliberations on the report. As for the other recognized sources of the detection of international corruption, it seems that a very marginal amount of them have been mobilized in Luxembourg. Indeed, an effective, efficient international corruption mechanism puts into question the awareness raising of public and private actors. We believe that Luxembourg should marshal more means of creating conditions that would support the discovery of corruption and working with the Committee for the Prevention of Corruption, COCRECO. We do also believe that Luxembourg must work harder to discover the risks of international corruption that its companies are exposed to and in so doing, we have to differentiate the passive bribe acceptance by foreign officials and the active bribing of foreign officials. We believe that this differentiation isn't yet fully implemented in Luxembourg and this is a problem because passive corruption committed by foreign officials seems to be properly understood whereas the risks relating to active bribing undertaken by Luxembourgish representatives abroad seem to be underestimated. So, there is an attention given to the product of money laundering but there seems to be far less attention given to active bribing by Luxembourgish representatives. So, this is unfortunate because it can certainly jeopardize Luxembourg's efforts. And now, my colleague will take the floor. Thank you, Lorenzo. Thank you, Chair. Now, I would like to speak to the implementation of the foreign bribery offence and other infractions, related infractions. First of all, we wish to congratulate Luxembourg because for the first time since the entry into the Pacific Convention, it has obtained the conviction for international corruption. However, the cases treated since then seem to treat influence trafficking as an alternative offence to active corruption. This is a pragmatic approach that has some merit but only as long as it can overcome some practical obstacles and ensure convictions. However, it does provide also some drawbacks because some of these infractions are not punished as severely. And more generally, we believe that it is unfortunate that there has been a very tentative implementation of this offence of international corruption since the implementation of the Convention. As mentioned, only one case has been judged and eight national persons have been convicted, but many other cases and suspected cases have not been pursued. The authorities have pursued some foreign corruption cases, but they have not been followed up on since phase three. Assessors do have seen the commitment and expertise of the judiciary that they met in Luxembourg, and not just the judges but all of their colleagues, prosecutors, etc. But even so, some structural and permanent solutions must be found to overcome the problem of resources that plague the entire criminal chain. The assessors are very pleased with the new criminal policy adopted by Luxembourg with regards to anti-money laundering. It now encourages the active pursuit of anti-money laundering. Unfortunately, since phase three, it seems that it has had limited effect despite the risks that Luxembourg is exposed to. And one important and ambitious constitutional reform, which was adopted on July 1st, 2023, so after our visit, seeks to strengthen and modernize the position of the judiciary. And we believe that the working group should follow up on this new measure. The adoption of guilty pleas under a plea bargaining system is welcome as this mechanism could foster the resolution of complex financial cases, which currently require a huge amount of time and energy. Regarding sanctions and forfeiture, the level of fines imposed to people in companies is still too low to actually have a deterrent effect, especially with regards to the extenuating circumstances. However, some legislative changes have been adopted since phase three in order to extend the scope of the forfeiture system and make its implementation much more effective. Luxembourg has always made significant efforts to strengthen its legislative framework in terms of mutual legal assistance, but despite the tangible results, Luxembourg still is not using its international cooperation tools quite enough. And our final observations bear on the responsibility of companies. We are very pleased with the adoption of a clause to engage the responsibility of enterprises. And we recommend that the authorities systematically examine the participation of Luxembourg companies in transnational corruption and assess the possibility of pursuing companies who might have been accomplices or intermediaries in this kind of offence. Finally, after this preparatory meeting, a report was changed in order to take into account some of the new developments and clarifications provided by Luxembourg. We also wish to thank the Luxembourg delegation for their very constructive and positive cooperation and their excellent state of preparation before, during, and after the visit. Finally, we would like to also thank the secretariat, which supported us every step of the way. And finally, my colleagues to the left, my left, have been wonderful colleagues throughout this assessment. Thank you very much. Thank you, Mr. Chair, ladies and gentlemen, dear colleagues. Thank you very much for allowing me to take the floor. I would like to introduce myself first. My name is Barbara Iliaki, and I am with the Ministry of Justice of Luxembourg. I am the new head of delegation of Luxembourg for the working group, and I'm very pleased to be working with you. I will also be giving the floor to the other members of the Luxembourg delegation, which are with me here today in person. Please. Hello, everyone. And I will be speaking in French. My name is Jean-François Boulot, and I am a joint prosecutor, assistant prosecutor, responsible for the financial aspects of the prosecution. I think most of you know me already. And I'm also with the Department of Justice of Luxembourg. Hello. My name is Francis Mekil, and I am head of the Identification and Discovery Office. Hello. My name is Paul Cataire. I am assistant director of the Financial Intelligence Unit. Thank you very much. I would also like to mention that we are here with a representative of the embassy, and we also have representatives of the Department of Mobility and Public Works, of the judiciary, of the insurance connoisseur, among others who are joining us online. Well, at least I hope they have been able to connect. I would also thank the assessors for their very detailed and conscientious work, as well, of course, as well as the secretariat, of course, for their support and availability every step of the way in this phase 4 evaluation. I would also like to take advantage of the opportunity to thank our national authorities for their effort and exemplary cooperation in answering the questionnaire during the visit in situ and for this week's preparations. Now, with regards to the contents of the report, we are pleased that the assessors have recognized the progress made in Luxembourg and the many institutional and legislative changes made by Luxembourg since phase 3. The fight against international corruption, of course, is a long-term fight, and it requires continuous engagement. We have made significant efforts in order to improve our legislative framework in keeping with the Convention and the OECD recommendations. As the evaluators have said, the new legislation adopted on 16th of May 2023 on protecting whistleblowers, which was about to enter into force during the on-site visit, has been analyzed by the assessment team, and it has been concluded that this is a very ambitious legislation that will protect whistleblowers and is based on international standards. And today, almost a year later, almost a year after the implementation of this legislation, we have experience with its implementation, and though there are some practical points that need to be ironed out, we are optimistic that this new law will indeed protect whistleblowers that detect and denounce violations. We have a detection and identification office under the Ministry of Justice that has been in operation since September, and they are here represented, and they support the authorities in implementing the different channels of detection and whistleblowing. It is also very active in terms of awareness-raising of the general public, of companies, and of the various authorities. I also wanted to mention the FATF Mutual Evaluation Report, which was published in 2023. In this report, the FATF recognizes the quality of the Luxembourg framework on anti-money laundering and fighting terrorism. The FATF believes that Luxembourg has achieved a very high quality level and has made huge efforts in this field. Another reform which entered into force in July 2023 is a constitutional reform, as mentioned by the evaluators, and it strengthens the status of the judiciary and explicitly clarifies their independence. We also have a new National Council of Justice, which supervises the functioning and the independence of the judiciary. It is an external power and is an autonomous organization, and it is now in charge of recruiting and appointing the judiciary. The evaluators have mentioned several times the problem of the insufficient human resources in terms of the judiciary, police services, and the financial intelligence unit, and they are right. It is true. That said, the government of Luxembourg, in its coalition accord of 2023 to 2028, did confirm the recruitment of new human resources in the police and the judiciary. Other major reforms of the last few years bear on the procedure of plea bargaining, which allows the prosecutors and the accused to suggest a sentence. This procedure allows us to shorten the procedure in court. Luxembourg has also extended its forfeiture regime and has implemented a new regime of forfeiture by equivalent. These are major innovations and have allowed us to create a bureau of the management and recovery of assets, and this allows us to have post-sentence asset investigations. Finally, regarding the responsibility of companies, we have a new clause to engage the corporate responsibility of companies. Finally, I would like to underscore the existence of a new criminal policy, which allows our prosecutors to assess mutual legal assistance requests for money laundering committed on the Luxembourg territory or abroad. Therefore, the prosecutors are encouraged to actively identify and discover any international corruption cases. So, we believe that we have made considerable progress since phase 3, which will of course support the prosecution efforts. Luxembourg has efficient, effective control measures to ensure the integrity of commercial transactions. Unfortunately, this progress has not always reflected any recommendations that have been made to us. Of course, we still have a long road ahead. Corruption requires constant work and cooperation with our national and international partners. We know that the work will not end with the adoption of this report. On the contrary, it is just the beginning of the hard work, and we are determined to implement the measures that will satisfy the high expectations of this group. Thank you very much. I welcome the new head of delegation to the WGB. We will go through paragraph by paragraph, so I will wait for the documents to be loaded on the screens. I remind you that we will not be going through the executive summary today. That will be done at the second reading, and we will be starting at paragraph 1 of the introduction. Okay, so I'm going to start with the introduction, so I'll be doing paragraphs 1 to 15 and commentary. Is there anybody who wants to take the floor? I should point out that I can't actually see the people on the screen. Is it possible to get those up? Okay, so if there's somebody on the screen, it's going to have to be flagged to me manually, which is fine. Okay, nothing on the screen. Thank you. Thank you, Chair. I'd like to thank the secretariat and the lead examiners for a very easy-to-read report. I'd like to comment that I especially like the new headings, where we don't just have a dry heading but something about the substance of the commentary. I thought that helped very much to read through the report, so thank you. I have a comment in the commentary after 15, in the second paragraph, where we say, particularly concerned by the lack of conviction. So I was wondering if we're specifically concerned about the convictions or actually lack of charges or investigations, or are we just concerned about the convictions? Thank you. Lead examiners, does anyone want to set up? Thank you for this question. Indeed, there was only one conviction. And of course, that is because there are a few criminal proceedings. Of course, we could talk about the scarcity of proceedings, but one thing is sure, there was only one conviction. But of course, everything is interrelated and interlinked. So we could probably indeed refer to the scarcity of criminal proceedings, which, of course, means that there is a conviction. I would like to specify that the investigations in this area are quite lengthy, so that might explain that the on-going cases are not so far that we are going to be able to produce them before the court. It takes some time also because of the international co-operation that is required. Yeah, thank you. I think that's an experience shared by everybody in the room. But I think what we're saying here is that we have only had one conviction. The reason we've only had one conviction is because there's been a scarcity of cases that could lead to convictions and only one has. So I think it's appropriate and I think it's a good comment by Israel, which I would say that one has led to, and that's endorsed by the lead examiners. So people happy with this change? The U.S., please. Thank you to my colleagues from Luxembourg. It's a great pleasure to have you here. And to the country examiners, excellent work on this very thorough report, which took me quite some time to read. So I'm giving you some thorough comments throughout. So my question is the next paragraph here, which says that the lead examiners believe there are several reasons for the lack of prosecution. And it says, quoting specifically to the economic and strategic importance of Luxembourg, that that dictates that priority be given to combating money laundering as part of its fight to the detriment of other economic offenses, including foreign bribery. So this particular comment popped out at me because it's not referenced as a reason anywhere else within the report. I mean, it's implied that there seems to be a tremendous emphasis on money laundering. But is that, in fact, the case that Luxembourg has prioritized resources to money laundering, and has that caused a detrimental effect in your ability to pursue foreign bribery? So if we could have a clarification on that, I would be greatly appreciative. Thank you. Thank you, U.S., for the comments. Luxembourg, do you want to address that? Merci beaucoup pour la question. Thank you very much for that question. Clearly, the fight against money laundering and terrorism is a strategic priority for Luxembourg, as reflected in our policies. But the report also mentions that these criminal proceedings policy has been changed in order to admit other priorities too. So we're not just limited to anti-money laundering. And the GAFI report shows and confirms that we've had good results with other offenses. In fact, the court also provides that we will provide human resources to all other financial and economic crimes, not just money laundering. And I'll give the floor to the state prosecutor. Yes, I can answer that question too. Luxembourg is a financial center, which means that we pay particular attention to discovering and pursuing money laundering committed in Luxembourg, including international corruption. Corruption is also a priority of the public prosecutor. These offenses are, in fact, the ones to which we devote probably the most resources. And the problem is actually at the level of the discovery of international corruption, not so much at the level of pursuing cases that are reported. And then, of course, there's the issue of international cooperation. Meaning that we come in with mutual legal assistance requests. We try to execute them as widely as possible, but we also examine them to see if there are any accomplices or offenders within Luxembourg for any given reported offense, including the offense of corruption. And in terms of international corruption, all these cases have one thing in common. They require a lot of investigation, a lot of work, and a lot of investigation abroad by other countries that have to cooperate with Luxembourg. So, in short, yes, as a financial center, we do concentrate on anti-money laundering, but corruption is right up there with it, and we have zero tolerance against this kind of offense. Thank you very much for that explanation. I think it's just because of the change you've made to the second paragraph, I think we're recognizing that it isn't just the convictions, it is the proceedings as well. So, while recognizing that cases take time and you need mutual legal assistance and resources to do them, what we're talking about here is the lack of cases in the first place. So, that part isn't necessarily as relevant to this part of the report because of that change. The question then is, the way the sentence currently reads, and this is the point I think the US is making, that because of the size of the economic and the importance of the financial center, the priority of Luxembourg is money laundering. I think what I've heard from Luxembourg is that corruption, including foreign bribery, is still a priority, but would it be fair to say that they're not the same priority, that money laundering and terrorist finance is perhaps the main focus? In which case, the sentence may be accurate, but we may want to tweak it just to reflect some of the feedback we've got. The two offenses are priorities for Luxembourg. We don't give priority to one over the other when it comes to these two crimes, the laundering or corruption. When we have corruption of a foreign public official in Luxembourg, very often there are financial flows and corporations or other persons that we want to prosecute. We have cases that are underway. Now it's difficult to say if there are enough or not. When it comes to priorities, we have a financial prosecutor's office and we have a division which is in charge of money laundering and there are judges, prosecutors who take care of international bribery, foreign bribery, they are the most experienced judges who take care of these cases. Thank you. I'll come to the UK in a moment. Do the governors, do they want to come in? And if so, you don't have a flag, do you? Do you have a flag in front of you? Because I can't see it from here. Yeah, you might want to pass them down so that we can see them. Thank you. I would like to reference, to make a reference to paragraph 154 in the first sentence during the visit. Maybe it has changed, but during the visit, that's the impression that we had. Just one second, I'll speak. The UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and I'm not sure if you can hear me, but the UK was just on this part of the panel, and also passive laundering that corresponds to the high risk for politically exposed persons. and also passive laundering that corresponds to the high risk for politically exposed persons. and also passive laundering that corresponds to the high risk for politically exposed persons. and also passive laundering that corresponds to the high risk for politically exposed persons. and also passive laundering that corresponds to the high risk for politically exposed persons. and also passive laundering that corresponds to the high risk for politically exposed persons. and also passive laundering that corresponds to the high risk for politically exposed persons. and also passive laundering that corresponds to the high risk for politically exposed persons. There is an enhanced CDD which is required, and it's very well defined in international norms, There is an enhanced CDD which is required, and it's very well defined in international norms, There is an enhanced CDD which is required, and it's very well defined in international norms, And that is maybe what leads to this impression that we don't pay enough attention to other aspects, And that is maybe what leads to this impression that we don't pay enough attention to other aspects, And that is maybe what leads to this impression that we don't pay enough attention to other aspects, And that is maybe what leads to this impression that we don't pay enough attention to other aspects, And that is maybe what leads to this impression that we don't pay enough attention to other aspects, And that is maybe what leads to this impression that we don't pay enough attention to other aspects, And that is maybe what leads to this impression that we don't pay enough attention to other aspects, And that is maybe what leads to this impression that we don't pay enough attention to other aspects, And that is maybe what leads to this impression that we don't pay enough attention to other aspects, And that is maybe what leads to this impression that we don't pay enough attention to other aspects, And for us prosecutors, corruption is a priority for transnational and local corruption, And for us prosecutors, corruption is a priority for transnational and local corruption, And for us prosecutors, corruption is a priority for transnational and local corruption, And for us prosecutors, corruption is a priority for transnational and local corruption, And for us prosecutors, corruption is a priority for transnational and local corruption, And for us prosecutors, corruption is a priority for transnational and local corruption, And for us prosecutors, corruption is a priority for transnational and local corruption, And for us prosecutors, corruption is a priority for transnational and local corruption, And for us prosecutors, corruption is a priority for transnational and local corruption, And for us prosecutors, corruption is a priority for transnational and local corruption, And for us prosecutors, corruption is a priority for transnational and local corruption, And for us prosecutors, corruption is a priority for transnational and local corruption, And for us prosecutors, corruption is a priority for transnational and local corruption, And for us prosecutors, corruption is a priority for transnational and local corruption, And for us prosecutors, corruption is a priority for transnational and local corruption, And for us prosecutors, corruption is a priority for transnational and local corruption, And for us prosecutors, corruption is a priority for transnational and local corruption, And for us prosecutors, corruption is a priority for transnational and local corruption, And for us prosecutors, corruption is a priority for transnational and local corruption, And for us prosecutors, corruption is a priority for transnational and local corruption, And for us prosecutors, corruption is a priority for transnational and local corruption, And for us prosecutors, corruption is a priority for transnational and local corruption, And for us prosecutors, corruption is a priority for transnational and local corruption, And for us prosecutors, corruption is a priority for transnational and local corruption, The lead examiners are saying that in practice, it may be that a greater prioritisation is given to taxing money laundering, The lead examiners are saying that in practice, it may be that a greater prioritisation is given to taxing money laundering, The lead examiners are saying that in practice, it may be that a greater prioritisation is given to taxing money laundering, The lead examiners are saying that in practice, it may be that a greater prioritisation is given to taxing money laundering, The lead examiners are saying that in practice, it may be that a greater prioritisation is given to taxing money laundering, The lead examiners are saying that in practice, it may be that a greater prioritisation is given to taxing money laundering, The lead examiners are saying that in practice, it may be that a greater prioritisation is given to taxing money laundering, The lead examiners are saying that in practice, it may be that a greater prioritisation is given to taxing money laundering, The lead examiners are saying that in practice, it may be that a greater prioritisation is given to taxing money laundering, The lead examiners are saying that in practice, it may be that a greater prioritisation is given to taxing money laundering, The lead examiners are saying that in practice, it may be that a greater prioritisation is given to taxing money laundering, The lead examiners are saying that in practice, it may be that a greater prioritisation is given to taxing money laundering, The lead examiners are saying that in practice, it may be that a greater prioritisation is given to taxing money laundering, The lead examiners are saying that in practice, it may be that a greater prioritisation is given to taxing money laundering, The lead examiners believe that Luxembourg's economic and strategic importance as a financial centre means that it prioritises the combating of money laundering as part of the fight against financial crime, perhaps to the detriment of the UK Government. The lead examiners believe that Luxembourg's economic and strategic importance as a financial centre means that it prioritises the combating of money laundering as part of the fight against financial crime, perhaps to the detriment of the UK Government. The lead examiners believe that Luxembourg's economic and strategic importance as a financial centre means that it prioritises the combating of money laundering as part of the fight against financial crime, perhaps to the detriment of the UK Government. The lead examiners believe that Luxembourg's economic and strategic importance as a financial centre means that it prioritises the combating of money laundering as part of the fight against financial crime, perhaps to the detriment of the UK Government. The lead examiners believe that Luxembourg's economic and strategic importance as a financial centre means that it prioritises the combating of money laundering as part of the fight against financial crime, perhaps to the detriment of the UK Government. The lead examiners believe that Luxembourg's economic and strategic importance as a financial centre means that it prioritises the combating of money laundering as part of the fight against financial crime, perhaps to the detriment of the UK Government. The lead examiners believe that Luxembourg's economic and strategic importance as a financial centre means that it prioritises the combating of money laundering as part of the fight against financial crime, perhaps to the detriment of the UK Government. The lead examiners believe that Luxembourg's economic and strategic importance as a financial centre means that it prioritises the combating of money laundering as part of the fight against financial crime, perhaps to the detriment of the UK Government. The lead examiners believe that Luxembourg's economic and strategic importance as a financial centre means that it prioritises the combating of money laundering as part of the fight against financial crime, perhaps to the detriment of the UK Government. The lead examiners believe that Luxembourg's economic and strategic importance as a financial centre means that it prioritises the combating of money laundering as part of the fight against financial crime, perhaps to the detriment of the UK Government. The lead examiners believe that Luxembourg's economic and strategic importance as a financial centre means that it prioritises the combating of money laundering as part of the fight against financial crime, perhaps to the detriment of the UK Government. The lead examiners believe that Luxembourg's economic and strategic importance as a financial centre means that it prioritises the combating of money laundering as part of the fight against financial crime, perhaps to the detriment of the UK Government. The lead examiners believe that Luxembourg's economic and strategic importance as a financial centre means that it prioritises the combating of money laundering as part of the fight against financial crime, perhaps to the detriment of the UK Government. The lead examiners believe that Luxembourg's economic and strategic importance as a financial centre means that it prioritises the combating of money laundering as part of the fight against financial crime, perhaps to the detriment of the UK Government. The lead examiners believe that Luxembourg's economic and strategic importance as a financial centre means that it prioritises the combating of money laundering as part of the fight against financial crime, perhaps to the detriment of the UK Government. The lead examiners believe that Luxembourg's economic and strategic importance as a financial centre means that it prioritises the combating of money laundering as part of the fight against financial crime, perhaps to the detriment of the UK Government. The lead examiners believe that Luxembourg's economic and strategic importance as a financial centre means that it prioritises the combating of money laundering as part of the fight against financial crime, perhaps to the detriment of the UK Government. The lead examiners believe that Luxembourg's economic and strategic importance as a financial centre means that it prioritises the combating of money laundering as part of the fight against financial crime, perhaps to the detriment of the UK Government. The lead examiners believe that Luxembourg's economic and strategic importance as a financial centre means that it prioritises the combating of money laundering as part of the fight against financial crime, perhaps to the detriment of the UK Government. The lead examiners believe that Luxembourg's economic and strategic importance as a financial centre means that it prioritises the combating of money laundering as part of the fight against financial crime, perhaps to the detriment of the UK Government. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. Je ne sais pas si quelqu'un a demandé un changement. 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