VZCZCXRO4775
RR RUEHAG RUEHDF RUEHIK RUEHLZ RUEHROV
DE RUEHHE #0121 0531436
ZNR UUUUU ZZH
R 221436Z FEB 07
FM AMEMBASSY HELSINKI
TO RUEHC/SECSTATE WASHDC 2996
INFO RUCNMEM/EU MEMBER STATES COLLECTIVE

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