TERRORISM FINANCE: FINLAND'S PLAYS BY EU RULES

UNCLAS HELSINKI 000121

SIPDIS

SENSITIVE
SIPDIS

EB/ESC/TFS, S/CT (PATTY HILL),IO/PSC (JOHN SANDAGE)

E.O. 12958: N/A
TAGS: EFIN ETTC FI KVPR PREL PTER KTFN
SUBJECT: TERRORISM FINANCE: FINLAND'S PLAYS BY EU RULES

REF: A. A. 06 SECSTATE 193615


B. B. SECSTATE 19366

C. C. SECSTATE 16917


1. (SBU) Econoff delivered reftel demarches to Juha Rainne,
Legal Officer at the Ministry of Foreign Affairs and
Finland's representative to the EU's Sanctions Working Group.
In response to the question raised reftel A, Finland does
not maintain a separate national list of banned terrorist
entities, but instead relies on the European Union's list.


2. (SBU) In response to reftels B and C, Rainne noted that
because the EU does not have an Executive Order similar to
the one described in reftel B ("Blocking the Property of
Weapons of Mass Destruction Proliferators and their
Supporters"),the Iranian entities designated by the U.S.
would not be put on an EU list per se. Nonetheless, Finland
shares U.S. designations widely in the government, looping in
the National Bureau of Investigation and other intelligence
agencies, which in turn notify commericial entities including
banks. If Finland discovers activitiy by individuals or
entities listed on the U.S. Specially Designated Global
Terrorist (SDGT) list in Finland who are not on the EU's list
(which rarely, if ever, happens),it examines national money
laundering statutes and other law enforcement related
legislation that might permit an asset freeze. Rainne noted
that money laundering provisions for freezing assets in
Finland are "quite comprehensive." By all accounts, however,
this is a theoretical exercise since Finland receives on
average less than ten calls a year from banks that have had
"close matches" but in the end clearly no definitive match.
Rainne stated that this was more a reflection of the low
volume of activity rather than a lack of diligence on the
part of bank officials.


3. (SBU) Responding to reftel C ("Freezing Assets of
Iranian Entitities and Persons Not Specifically Listed in the
Annex"),Rainne confirmed that the approval process for the
EU regulation providing implementing authorities for
resoultion 1737 is well underway, with the first stage likely
to be concluded next week. It provides flexibility for the
EU to include the organizations listed reftel, and while he
did comment on them specifically, he believed that many of
the organizations on the U.S. list would be added to the EU
list. Rainne described Finland's role in EU decisionmaking
on this issue as one of " promoting consensus." Finland does
not usually block decisionmaking in the EU, preferring
instead to raise issues in working groups and during
negotiations, not "squelch the whole effort at the very end."

WARE