4  BIS Review 85/2009  We can have the best laws to combat money laundering, the best system to prosecute the offenders but if we lack the human capacity to implement them, then our efforts will be in vain. Hence, building local capacity must therefore be at the forefront of our efforts. The same concern applies to NPOs. That is, building capacities within the structures of our NPOs to be able to identify suspicious transactions and reporting them to the Money Laundering Prevention Authority (MLPA) is an important feature of Samoa’s anti-money laundering and countering terrorist financing activities regime. I understand that the MCIL may need to incorporate in its existing legislation some requirements for NPOs to comply with anti-money laundering measures and requirements. Some key requirements would include proper customer identification. That is, the NPOs must have a good understanding of who their customers are and their sources of funds as well as the purpose of conducting financial transactions through or with them. Another important requirement relate to the proper keeping of books and records that would assist any investigation that may involve information or records of NPOs. Conclusion In concluding, I should reiterate that it is everyone’s responsibility to do something about protecting Samoa from the offence of money laundering and terrorist financing activities. And, although one of Government’s principal and ongoing task is to increase public awareness, there is still a lack of common knowledge within the public domain of what constitutes a money laundering offence.
For example, we do not have a system where the private sector will share risks across borders, where capital and liquidity are fungible in pan-European financial institutions. A common deposit insurance would help, but it’s important to allow a European bank to be able to operate in the euro area as a single entity. Not all banks would be able to do that, but we need to have a timetable where we say, four or five years from now the banks that qualify in terms of quality and quantity of capital will get a European license. You need to put a very serious, technical, timetable for that, and announce it. That would create a new environment for banking. Is there a challenge to the ECB’s credibility because of the change of stance on the effective lower bound of rates? The story of the lower bound is a very simple one. For all non- standard measures there is not much historical experience, there was very little academic literature until recently. Many central banks thought the zero lower bound is zero, and when we initially decided to go for –0.1, we were not fully sure of the total impact on financial conditions in general and especially on banking. The negative deposit rate, like most non-standard measures – the forward guidance of July 2013, the LTROs starting in 2011, the TLTRO and the APP – delivered more than we expected in terms of their impact on financial conditions.