Policy and Procedures Working Group (PPWG)
The PPWG develops operational policy and provides advice on strategic issues impacting the Egmont Group, including the effective exchange of information and adherence to international standards.
The PPWG provides a forum where Egmont Group member FIUs can identify important operational policy and strategic issues and respond to them by coordinating a response across the organization and, in some instances, with partner organizations. The PPWG also supports the Egmont Group’s relationships, including partners such as the Financial Action Task Force (FATF).
The PPWG provides strategic advice to assist the Egmont Committee and the broader Egmont Group. The PPWG assists the other working groups with implementing operational findings or developing related policies or advice. As the custodian of the Egmont Group’s core documents, the PPWG ensures they remain consistent with the organization’s strategic plan and continue to be relevant to the global anti-money laundering and counter-financing of terrorism (AML/CFT) environment.
Key Elements of the PPWG'S Mandate
Chair and Vice-Chairs
Key Elements of the PPWG's Mandate
- Exploring potential solutions to multiple issues that impede the free exchange of information between FIUs;
- Promoting the understanding of Egmont Group standards and facilitating their common interpretation and uniform application;
- Assisting FIUs in developing strong relationships with reporting entities, including through feedback on STRs and other reports and, when possible, provision of information by FIUs to reporting entities to assist in detecting suspicious activity;
- Discussing and analyzing AML/CFT regulatory and supervisory issues/actions as they impact FIUs to identify relevant AML/CFT risks, trends, and methods that would mitigate risks identified by FIUs; and
- Addressing strategic issues and matters of principle within the Egmont Group, including cooperation between FIUs and the respective working groups.
Current PPWG Projects
- Revision of the Support and Compliance Process
- FIU Funding Models
- Creating a provision for the EG to protect its interest against geopolitical incidents
- MOU multilateral information exchange
- IndiE – Understand better the FIU Boards
- Dissemination strategy options for EG documents & the respective visualization
- Guidelines for MOUs between FIUs-LEAs
- Developed a Glossary of Key Egmont Group Terminology to enhance international cooperation.
- Created the framework for the development by the Egmont Committee of the 2018-2021 Egmont Group Strategic Plan;
- Developed a new succession planning model for the Chair of the Egmont Group that entails the creation of two new Egmont Group Vice-Chair positions while maintaining the Chair’s mandate at two years;
- Reviewed the terms of reference and the selection procedure for the Chair of the Egmont Group and developed terms of reference and selection procedures for the newly created Egmont Group Vice-Chair positions;
- Revisited the Egmont Group’s Support and Compliance Process and reviewed its Procedural Trigger 3 to consider Mutual Evaluation reports (MERs) effectiveness findings when determining whether member FIUs comply with the Egmont Group requirements listed in the Egmont Group Charter and Principles for Information Exchange;
- Developed an Egmont-FATF Engagement Framework that identifies the main areas of cooperation between the two organizations and proposes actions to enhance the synergies between them;
- Looked into the matters impacting on FIU autonomy and operational independence and contributed to the development of a paper that will assist governments (decision and policymakers), FIUs, and key stakeholders in identifying the features of an independent and autonomous FIU;
- Conducted an organization-wide needs assessment for translating Egmont Group documents and prepared, together with the Egmont Group Secretariat, a budget proposal approved by the HoFIU.
Chair and Vice-Chairs
Working Group Chair
Elvira Kross, MOT-Aruba
Chair, Policy and Procedures Working Group, 2021
Elvira Kross is a Policy and Legal Advisor at FIU-Aruba and a participant in the National Anti-Money Laundering and Counter-Financing of Terrorism Steering Group of Aruba. She has a master’s degree in law, specialized in criminal law. For almost 11 years, she worked as the legal assistant public prosecutor (portfolio holder of corruption, fraud, and money laundering), before her transfer to FIU-Aruba over 10 years ago. In the Egmont Group, Elvira participated in the former Legal Working Group and in the Policy and Procedure Working Group as Vice-Chair. She also participated in the Membership, Support and Compliance Working Group as a sponsor for candidate Egmont Group members and as a legal expert.
Additionally, Elvira is a member of the committee of appeal for a school community and the rapporteur of the prison system (ensuring the rights of detainees).
Elvira approaches her duties with great passion, enthusiasm, and dedication.
She is a fan of the performing arts, especially classical ballet.
- Najwa Benmadani – UTRF-Morocco
- Patricia Kordesch – FIU Germany