Vol. 2, Issue 11
Taiwan and Global Issues – Global Taiwan Brief Curated Series
Curated by Melissa Newcomb
Deportations and Taiwan’s Threatened International Space
By: Melissa Newcomb
Taiwan’s Commitment to Global Women’s Empowerment
By: Gloria Kuo
Taiwan: Modeling Effective, Holistic Pandemic Preparedness and Response
By: Jonathan Schwartz
Anti-Money Laundering Efforts in Taiwan and Directions for the Future
By: Wang Yuh Woei
This week’s issue marks the first of the Global Taiwan Brief’s curated series. The curated GTBs are special issues that focus on a central theme. The theme of this issue is on Taiwan’s global impact. Although Taiwan is not a formal member of the United Nations, and must participate as an observer in many multilateral organizations, Taiwan has demonstrated a commitment to finding solutions to many contemporary world challenges. Specifically, this issue highlights Taiwan’s policies on transnational finance, pandemic response, and women’s empowerment.
Deportations and Taiwan’s Threatened International Space
Melissa Newcomb is the Research Manager at the Global Taiwan Institute and the Associate Editor of the Global Taiwan Brief.
On February 17, the Spanish government approved the extradition of about 200 Taiwanese people to the People’s Republic of China (PRC) on telecom fraud charges. This act represents the latest in a series of deportations of Republic of China (ROC) citizens to the PRC and conducted in tandem with the marginalization of Taiwan in multilateral organizations and in its formal diplomatic relations. The extrajudicial deportations conducted by the PRC against private citizens of Taiwan are a dangerous subversion of international norms meant to intimidate Taiwan’s government and its people.
The first wave of deportations began in April 2016, when the PRC escalated from marginalizing Taiwan in international organizations to essentially kidnapping Taiwanese citizens from Kenya. On April 5, a group of Chinese-speaking foreigners were acquitted of cybercrime charges in Nairobi. The group included 23 Taiwanese citizens, eight of whom were deported to China against their will on April 8. The remaining 15 were then deported to China on April 12. By the end of April, 45 Taiwanese citizens were in custody in the PRC, though it remains unclear as to where the other 22 were arrested. Shortly after the deportations from Kenya, Beijing sanctioned a loan for $600 million.
Similar deportations took place across the world. Earlier in March 2016, 52 Taiwanese were arrested in Malaysia for charges of telecom fraud. Of those arrested, 20 were returned to Taiwan in April and later released, much to the PRC’s anger. The remaining 32 Taiwanese, however, were deported to China in May with a larger group of PRC citizens when Malaysia succumbed to pressure from China. Next, the Cambodian government deported 25 Taiwanese in June and another 13 Taiwanese in September to the PRC. Armenia followed suit in September, deporting 78 Taiwanese suspects of telecom fraud. Vietnam was the first country to follow this trend in 2017, deporting four Taiwanese in January. If the past year is any indication, we can only expect to see more extrajudicial deportations of Taiwan’s citizens to the PRC.
Taken in isolation, the deportations would be alarming enough—that they are occurring in tandem with diplomatic measures by the PRC to further isolate Taiwan only underscores their significance. The first diplomatic attack came in March 2016, when China played its hand and re-established ties with The Gambia, three years after the African nation formally recognized the “One-China” policy. It was a less-than-subtle symbolic action signaling to Taiwan’s President Tsai Ing-wen of things to come if she did not make a commitment to the so-called “1992 Consensus,” the agreement formed between the Chinese Communist Party (CCP) and the Nationalist Party (KMT) that each side of the Strait could hold its own interpretation of the “One-China” policy. In December, Beijing reinstated formal ties with São Tomé and Principe.
Apart from picking off formal diplomatic partners, Beijing squeezed Taiwan’s ability to join multilateral organizations throughout 2016. Although Taiwan is not recognized as a “nation” by the UN, Taiwan has attended the annual World Health Organization’s (WHO) assembly as an observer since 2009. However, for the first time in May 2016, Taiwan was invited under the auspices of the “One-China” policy. In the same month, Beijing cut off official communications with Taiwan shortly after President Tsai’s inauguration, probably because she did not explicitly “accept” the 1992 Consensus in her speech, although she did acknowledge the fact that the meetings took place. In September, Taiwan was snubbed from the important International Civil Aviation Organization’s (ICAO) global safety meeting because Beijing claims it as an “inseparable part of China,” in the words of Chinese Foreign Ministry spokesman Lu Kang (陸慷).
Banning Taiwan from participating in multilateral forums such as the ICAO, and limiting its role in the WHO jeopardize the security of Taiwan’s populace, and also the world population. Taiwan’s Civil Aeronautics Administration (CAA) oversees the Taipei Flight Information Region, which covers 180,000 nautical miles (nm). For the last 40 years, Taiwan has not had direct access to the safety regulations of the ICAO, and yet it handles the safety of 58 million travelers annually and is connected to 135 cities. Globally, Taiwan ranked 12th in volume of international passengers in 2016 (for perspective, the highest ranking US city was New York at 16th). All this is to say that the exclusion of Taiwan does more harm than good for everyone, except the PRC government.
Taken together, the deportations of accused Taiwanese and the strategic reduction of Taiwan’s diplomatic partners demonstrate Beijing’s aggressive “diplomacy warfare” against Taiwan. International organizations and the foreign policy community have been conditioned to accept a certain level of bullying from China against Taiwan. However, if the PRC is not held accountable for its actions regarding the deportations, a dangerous precedent will be set. China will be emboldened to continue taking actions against Taiwan’s private citizens and violate other international norms to meet its foreign policy interests. If we extend Beijing’s logic for the deportation of Taiwanese citizens to the PRC, any person of interest who carries a ROC passport could be “claimed” as a PRC national. As Kenya’s Home Affairs Ministry spokesman, Mwenda Njoka, said, “[The suspects] came through China, so let them go back there. Let them deal with China. That is their problem.” Other countries, reliant on the PRC for trade, investment, or development aid, have already begun to adopt similar approaches to please their patron-state.
Following Spain’s deportation ruling, China defended its actions, saying that the deportations “[have] won widespread international approval.” Though there is no evidence of international praise, there also has not been enough of an outcry. The complicity of the countries involved in sending private citizens to a third-party country is disturbing. The people accused of crimes may indeed be guilty, but without even having a trial in the country where the crimes were committed, they are being transported to China, whose judicial system is notoriously corrupt. Or, in the case of Kenya, even if they are acquitted by the country’s court, they may still be sent to the PRC. The power-play by the PRC demonstrates its superior international influence and threatens the personal safety of Taiwan’s citizens who, while traveling abroad, may suddenly find that their host country considers them citizens of the PRC, subject to its government and law enforcement.
In the subsequent articles of this curated GTB issue, readers will learn and hopefully appreciate how Taiwan’s government and policymakers work to address issues for the betterment of its people, and the international community. As the US struggles to adapt its national security policies to handle unconventional threats such as cyber warfare and sophisticated non-state actors such as ISIS, it is imperative to maintain the integrity of international laws designed to enhance cooperation and reduce violent conflict. If any state openly uses a heady combination of investment and development to bribe other states into violating due process and capturing private foreign citizens, the security concerns become overwhelming. Thus, the deportations of accused Taiwanese criminals is not an internal issue or a regional spat about judicial procedures, but a series of acts that harms the integrity of international norms.
The main point: Taiwan’s international space and the freedom of its civilians were increasingly threatened throughout 2016 by the PRC government. Deporting Taiwanese from third-party countries to the PRC involved complicity by host countries as well as a violation of international norms by China. The US and other nations should work to preserve and expand Taiwan’s international participation because of its ability to contribute to solutions for global challenges that impact the world.
Taiwan’s Commitment to Global Women’s Empowerment
Gloria Kuo is a Political Division Officer at the Taipei Economic and Cultural Representative Office in Washington DC.
A hallmark of Taiwan today is the high level of participation by women at all levels of society. The empowerment of women contributes to Taiwan’s economic growth, political stability and social progress. It represents not only progress within Taiwan but showcases an important asset that Taiwan presents to the world.
Taiwan’s progress on women’s empowerment is significant. The election of Tsai Ing-wen as the first female head of state in Taiwan in 2016 is the most obvious example. President Tsai is not the first female chief executive in Asia, but she is the first female elected leader in the region whose political career did not originate with a political family or the political career of a spouse. Her election was the direct result of her achievements as a professional in academia and as a trusted figure in Taiwanese government circles.
Women have held important political positions in Taiwan before President Tsai’s election. Annette Lu was vice president from 2000-2008. Membership in the Legislative Yuan is now 38 percent female, significantly ahead of the international average of 22 percent, and the current leader of the largest opposition party, the Kuomintang (KMT), is Chairwoman Hung Hsiu-chu.
The empowerment of women is about giving all women the tools they need to play a greater role in society and the economy for protecting families, which require a solid economic foundation. Women in Taiwan in 2015 earned 83% of their male counterparts. Mothers in Taiwan receive full pay during eight weeks of maternity leave and 60% of their salary for their next six-month infant care leave. Also, companies in Taiwan employing 100 workers or more are required to provide nursing rooms and childcare facilities. Taiwan’s sound record on women’s empowerment issues is reflected in the United Nation’s Gender Inequality Index (GII). In 2014, Taiwan took fifth place out of 155 countries worldwide, as measured by the index.
At the International Women’s Executive Committee meeting in November 2016, President Tsai committed to raising the female labor force participation rate, which stood at 50.74 percent in 2015, the level at which it has remained for several years. President Tsai’s pledge came as part of the government’s effort to support women at work, which includes equal wages, parental leave, promotions and child care support.
Gender equality is a key area of cooperation with the United States. The close ties between the United States and Taiwan are based on shared values of democracy, economic freedom, and human rights, as well as close economic and security ties. As part of the relationship, both sides are committed to the empowerment of women, recognizing that the substantive involvement of women in economic activities naturally contributes to stronger economic performance in our respective countries. In addition, when Taiwan and the United States work together to facilitate the empowerment of women in developing countries, they are also promoting economic growth in other parts of the world.
In 2015 Taiwan and the United States established Global Cooperation & Training Framework (GCTF), a bilateral mechanism through which both sides can address global challenges by providing training projects around the world. The key areas for 2016 included women’s empowerment, public health, energy efficiency and Information Communication Technology (ICT). An early GCTF project related to women’s empowerment was the workshop, Enhancing Prosperity and Opportunity for Women in the Asia-Pacific Region, held in Taipei in March 2016. Kurt Tong, then U.S. Principal Deputy Assistant Secretary of State for Economic and Business Affairs noted the conference would “bring together government and civil society leaders, primarily from the Asian and Pacific region, to discuss ways that we can promote and create political and economic empowerment to women and create a more inclusive society.” The workshop was intended to formulate policies, and to share practical experiences and models of successful female-run businesses in the region.
Melanne Verveer, the first U.S. Ambassador-at-Large for Global Women’s Issues, visited Taiwan in September, 2016, attending the two-day Conclusive Meeting of Innovation for Women and Economic Development Project, sponsored by the Gender Equality Committee of Taiwan’s Executive Yuan (the Cabinet). Her visit highlighted the joint efforts of Taiwan and the US to bring attention to women’s issues, as well as to increase momentum for endeavors by both countries to promote gender equality throughout the world.
In addition to empowering women at home, Taiwan is pursuing the empowerment of women internationally through the Asia Pacific Economic Cooperation forum (APEC). The most recent and significant step taken by the United States and Taiwan came at the November 2016 APEC Summit in Peru, where the two sides announced the intention to create an APEC sub-fund on women and the economy. Dr. James Soong, Taiwan’s Special Envoy to the Summit, emphasized that the sub-fund will support the five pillars of the APEC Policy Partnership on Women and the Economy: access to capital, access to market, skills and capacity building, women’s leadership and innovation and technology. US senior officials pointed out that, through the new sub-fund, “APEC economies would be able to apply for funding to support new or existing APEC initiatives focused specifically on women’s economic empowerment.”
The joint efforts on women’s empowerment within APEC are just one element of the strong Taiwan-US relationship, which has persisted through different US administrations and which enjoys bipartisan support in the US Congress. Our bilateral cooperation on economic issues, including women’s economic empowerment, contributes to economic growth worldwide. This partnership truly demonstrates how much Taiwan and the U.S. can achieve together to make the world more secure, freeand prosperous.
The main point: Taiwan boasts a high level of participation by women at all levels of society. The empowerment of women contributes to Taiwan’s economic growth, political stability and social progress. Taiwan is committed to empowering women all over the world through its activities in multilateral forums such as APEC and in its partnership with the US.
Taiwan: Modeling Effective, Holistic Pandemic Preparedness and Response
Dr. Jonathan Schwartz is Professor of Political Science and director of the Asian Studies program at the State University of New York at New Paltz. Professor Schwartz conducts research on factors influencing effective pandemic response with a focus on East Asia.
On March 2, 2017, Taiwan suffered its first Avian Flu-related (H7N9) death. The man contracted the disease while visiting China, and died despite a month of intensive treatment in Taiwan. This is but one example of the increasing threat of global pandemics, a threat that has sparked concern among government officials and the general public. Driven by these concerns and its past experiences with pandemics, Taiwan has experimented with new approaches to preparedness and response. Given its efforts, Taiwan should be viewed as providing a useful example of innovative pandemic response.
Pandemics have come and gone throughout history, but over the past 15 years in particular there has been growing awareness that conditions are becoming increasingly ripe for a significant globe-spanning outbreak. Indeed, over this timespan, there has been no shortage of pandemics, though none yet exhibiting characteristics of virulence and infectiousness that could in combination result in major global disruption.
The 2002-2003 Severe Acute Respiratory Syndrome (SARS) outbreak originating in China was a shot across the bow – a warning of the potential damage pandemics may cause. The SARS case-fatality rate (the number of people who sickened and died) was 14-15 percent overall and over 50 percent for people over 64 years of age. These numbers are distressing, and yet at the conclusion of the outbreak the WHO identified only 8,447 confirmed cases and 916 deaths worldwide. Of course, the impact of SARS extended well beyond infections and case-fatality rates. SARS had a significant psychological and economic impact as well. Indeed, the World Bank estimates that SARS caused a global GDP decline of $33 billion over its 7-month span.
That even the relatively limited SARS outbreak could have such a massive impact underlines the potential devastation of a highly virulent and infectious disease. For example, if an equivalent to the Spanish flu (which lasted from in 1918-1919, infected one-third of the then global population, and killed between 20-50 million) were to occur today, it would potentially kill over 100 million people worldwide and cut global economic output by over $3 trillion. Since SARS, we have experienced Highly Pathogenic Avian Influenza (Bird Flu), swine flu, Ebola, Middle East Respiratory Syndrome (MERS), dengue, Zika, and continue to fight AIDS worldwide. Again, while none have yet risen to the level of a globe spanning, easily transmissible, and virulent pandemic, each has underscored the potential threat.
The international public health community, led by the World Health Organization (WHO), continues to update and improve existing protocols, policies, and early warning systems, in order to facilitate cross-border cooperation. However, the WHO also acknowledges that successful pandemic response requires effective domestic response capacity, something that no country yet possesses.
The Health Belief Model suggests that perceived susceptibility drives individual behavior as regards pandemic threats. Only populations that have experienced a pandemic are likely to take the threat seriously and invest in preparation. Having experienced major recent pandemics, Taiwan—as predicted by this model—has taken the threat of a future pandemic seriously and made a variety of innovative efforts to develop effective response capabilities.
One notable initiative taken by Taiwan conforms with the “whole-of-society” approach to pandemic response. States generally focus on comprehensive public health plans, high technology medical tools, physician care, vaccination and immunization protocols and public awareness building. These are all essential, and yet alone are inadequate. In line with the whole-of-society approach, research I conducted finds that improved outbreak control requires that states also invest in cooperation and trust building with local communities. This involves drawing on local actors to supplement government actions by distributing resources for disease control, disseminating information to educate the public, mobilizing volunteers, and ensuring community interests are represented while fostering equitable access to resources and trust in government institutions.
Taiwan’s government invests in traditional, state-led pandemic preparedness as described above. But in addition, the Taiwan CDC works closely with schools, elderly care facilities, prisons, and international entry points to track and contain as necessary diseases with pandemic potential. The Taiwan CDC also works with local hospitals and the private sector (e.g. hotels) to identify and treat potential cases early on. Perhaps the most important innovation, however, has been the government’s work with societal actors.
In line with the whole-of-society model, Taiwan’s government has invested in close coordination between public health officials and community leaders. Focusing on the li (里) or neighborhood level, the Taiwan CDC has been training and supporting neighborhood wardens, known as li zhang (里長), in epidemic-related prevention and control activities. The neighborhood warden is a non-state actor residing below the lowest level of government, who functions as an elected liaison between his/her neighborhood (averaging 5,800 residents) and the state. Usually a longtime resident of the community and familiar with its residents, the warden represents the community’s interests to the government, while also facilitating government resource deployment locally.
Recognizing the potential for wardens to play a constructive role, the Taiwan CDC in 2016 initiated a program to train wardens in dengue prevention and response. Focusing on Kaohsiung and Tainan, this initiative was a response to the historically unprecedented 2015 dengue outbreak in which these two cities suffered over 42,000 infections. The wardens cooperate with the CDC and local public health officials, foster community trust and offer an avenue to convey important outbreak-related information, mobilize the community, and engage in activities that diminish pandemic risk.
A recent example illustrating the effectiveness of this approach is the Taipei CDC’s cooperative work with wardens during the November-December 2016 Taipei Dengue outbreak. Working together with public health officials, the wardens identified potential and existing breeding grounds for dengue-bearing mosquitoes while also providing information to their communities at the individual level on how to prepare for and avoid infection.
This cooperative effort has been identified by Dr. Yen Muh-yong, from the Taipei City Hospital Division of Infectious Disease, as playing an important role in Taipei’s successful dengue response. Although it would be incorrect to attribute successful outbreak containment solely to the contributions of wardens, it is clear that they played an important role in supporting response efforts.
The main point: Taiwan’s example of outbreak prevention and containment is instructive, as equivalents to its neighborhood system that exist throughout the region. Indeed, they can be found in China, Japan, Vietnam, and Singapore (among others). As the number of outbreaks grows, these countries would benefit by drawing on Taiwan’s experience with whole-of-society pandemic preparedness and response.
 ProMED-mail. PRO/AH/EDR> Avian influenza, human (28): China (GX) Taiwan, H7N9, mutation. ProMED-mail 2017; 02 Mar: 20170302.4874114. <http://www.promedmail.org/post/4874114>. Accessed 02 March 2017.
 Kate E. Jones et al., ‘‘Global Trends in Emerging Infectious Diseases,’’ Nature 451 (February 2008): 21, 990–94, doi: 10.1038/nature06536.
 Jonathan Schwartz and Muh-yong Yen “Toward a Collaborative Model of Pandemic Preparedness and Response: Taiwan’s Changing Approach to Pandemics,” Journal of Microbiology, Immunology and Infection (2016), doi: http://dx.doi.org/10.1016/j.jmii.2016.08.010.
Anti-Money Laundering Efforts in Taiwan and Directions for the Future
Wang Yuh Woei is a professor and the Chair of the Terrorism Research Center of Central Police at the University of Taiwan in Taipei.
Money laundering is a mutual concern for governments around the world. The leaked April 2016 Panama Papers (巴拿馬文) revealed to the international public how pervasive money laundering, corruption, embezzlement, tax evasion, and smuggling are around the world. The Taiwan government is no exception in the struggle against such criminal activities. Indeed, Taiwan was implicated in the leaks, and in September 2016 the New York Department of Financial Services (NYDFS) imposed a fine on the Taiwanese bank Mega ICBC’s New York Branch (兆豐銀行紐約分行). Citing the Suspicious Transactions Report (SAR) (可疑交易的通報), Mega Bank was charged for legal non-compliance—breaching the US Bank Secrecy Act (BSA), to be specific. The Mega Bank case is an example of the vital role that the Taiwan banking system could play in countering money laundering.
In recent years, countries around the world have devoted greater attention to combating money laundering. Firstly, this is because it has become more important to ensure the transparency of money flows in order to impede terrorism financing. Secondly, it is necessary for governments to reduce money laundering in order to combat corruption and lower the possibility of embezzlement, which prevents wealth disparity and facilitates social progress. Thirdly, preventing money laundering allows economic activity to proceed normally; when present, money laundering enables crimes such as fraud, tax evasion (逃漏稅), and tax avoidance (避稅).
According to statistics provided by international organizations, the amount of money laundered globally in one year is $800 billion, or $2 trillion in current US dollars, which is 2-5 percent of global GDP. Such a large sum of lost money makes it necessary for countries around the world to work together to seek common solutions. It is critical that Taiwan comply with the increasingly strict financial rules and regulations promulgated in the United States for overseas finance, given that the United States is a major trading partner for Taiwan, North America is the largest market in the world, and the US dollar is the main currency used in transnational transactions. The Asia/Pacific Group on Money Laundering (APG), an independent international organization, will conduct the third evaluation of Taiwan in 2018. Failing the evaluation will mean that the normal operations of financial institutions in Taiwan will be negatively affected, and overseas financial business and operations will be restricted to some degree or even banned. The government of Taiwan, therefore, has been making increasingly greater efforts to intensify legislation on the legal level and implement anti-money laundering measures on the administrative level. These efforts include:
On the legal level, the Financial Supervisory Commission (FSC, 金融監督管理委員會) has revised the Precautions for Banks in terms of Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) (銀行業防制洗錢及打擊資助恐怖主義注意事項). Apart from referring to international legislation promulgated by the United States, New Zealand, and Hong Kong, and re-examining the 40 suggestions given by the Financial Action Task Force on Money Laundering, the revision of the Money Laundering Control Act (洗錢防制法) has also been completed and will likely be implemented in June 2017. The formulation and updates of rules and regulations will help shape the financial system, and contribute to the establishment of a sound banking system through the collective discipline mechanism (集體自律機制), autonomous shaping (自主的型塑), and stronger legal compliance culture(法遵文化).
Anti-money laundering measures focus on four prongs: first, strengthening the rules and regulations concerning anti-money laundering and counter-terrorism (健全防制洗錢及打擊資恐法制); second, providing supervision of financial institutions in the implementation and execution of these rules and regulations (督導金融機構落實執行); third, enhancing the capacity of financial institutions for anti-money laundering and counter-terrorist actions (提升金融機構防制洗錢及打擊資恐能力), and fourth, intensifying training and promotion (加強訓練與宣導).
The FSC, for example, has sorted through the various cases and created categories of 20 “suspected money laundering situations” (「疑似洗錢」態樣) for the Banking Association (銀行公會), demanding that bankers make greater prevention efforts. The FSC also demanded that special anti-money laundering divisions be established inside financial institutions by April 2017, that an Anti-money Laundering Office (洗錢防制辦公室) be established in the Executive Yuan, that banks confirm the information of the ultimate beneficiary when a corporate client intends to make a cross-border transfer higher than 30,000 NTD (US $950), and other measures.
Meanwhile, in order to prevent money laundering, the government has committed to making more efforts to confiscate the illegal benefits obtained in malfeasant economic activities. Jeweler’s shops, accountants, lawyers, land administration agents, and people from other non-financial industries will be obligated to report acts of money laundering. Efforts shall also be made to track the money flows of politically prominent persons, their relatives and trusted aides. These efforts will require more intensive anti-money laundering training within financial institutions, cultivation of professional anti-money laundering talents, the institution of exams to obtain anti-money laundering certificates, and so on. International anti-money laundering symposiums are also on the agenda, like the Symposium on the Developments in US Bank Secrecy Act and Money Laundering Control Act (美國銀行保密法與洗錢防制法之發展趨勢研討會) held jointly by China Trust and the Taiwan Academy of Banking and Finance in December 2016, and the Seminar for Overseas Managers, Legal Compliance Officers and Internal Auditors (海外分區經理人、法遵人員暨內稽內控研討會), held in New York by The Bankers Association of the ROC in January 2017, and so on.
As the providers of all kinds of convenient financial services, financial institutions are often exploited by criminals as the channels for their money laundering or financial terrorist activities. That is why the outcomes of anti-money laundering efforts and efforts to combat terrorist financial activites made by governments around the world are also dependent on the implementation of various prevention and control measures in financial institutions.
As a founding member of APG and a member of the international community, Taiwan stands ready to join the fight against money laundering and terrorist financial activites. Moreover, given that the business risks for the banking industry are far higher, it is now necessary for regulatory authorities to gradually move from a passive approach of identifying and correcting past errors toward a regulatory mechanism oriented toward risk management and active prevention. Even after the establishment of a proper legal compliance system, results will depend on whether the system is implemented and executed in practice.
The main point: The Panama Papers, released in April 2016, shed light into the dark recesses of the illicit global financial market, which fuels illegal money laundering and international terrorism. Taiwan’s banking industry was implicated in the papers and the government of Taiwan has been increasing its efforts to intensify legislation on the legal level and implement anti-money laundering measures on the administrative level.