REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND TO THE COUNCIL based on Article 8 of the Council Decision 2007/845/JHA of 6 December 2007 concerning cooperation between Asset Recovery Offices of the Member States in the field of tracing and identification of proceeds from, or other property related to, crime
Date: 2011-04-12
Institutions: European Commission
Subjects: confiscation of property, cross-border cooperation, economic offence, exchange of information, fight against crime, organised crime

EN 

EN 

   EN 

 
 
EUROPEAN COMMISSION 

Brussels, 12.4.2011 
COM(2011) 176 final 

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND 
TO THE COUNCIL 

based on Article 8 of the Council Decision 2007/845/JHA of 6 December 2007 concerning 
cooperation between Asset Recovery Offices of the Member States in the field of tracing 
and identification of proceeds from, or other property related to, crime  

EN 

   EN 

 
 
 
  
REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND 
TO THE COUNCIL 

based on Article 8 of the Council Decision 2007/845/JHA of 6 December 2007 concerning 
cooperation between Asset Recovery Offices of the Member States in the field of tracing 
and identification of proceeds from, or other property related to, crime  

1.1. 

Background 

INTRODUCTION 

Council  Decision  2007/845/JHA1  (“the  Decision”)  obliges  Member  States  to  set  up  or 
designate national Asset Recovery Offices (“AROs”) as national central contact points which 
facilitate,  through  enhanced  cooperation,  the  fastest  possible  EU-wide  tracing  of  assets 
derived  from  crime.  The  Decision  allows  the  AROs  to  exchange  information  and  best 
practices, both upon request and spontaneously, regardless of their status (administrative, law 
enforcement  or  judicial  authority).  It  requests  AROs  to  exchange  information  under  the 
conditions laid down in Framework Decision 2006/960/JHA2 (“the Swedish Initiative”) and in 
compliance with the applicable data protection provisions.  

The Decision is also intended to support the CARIN (Camden Assets Recovery Inter-Agency 
Network),  a  global  network  of  practitioners  and  experts  aimed  at  enhancing  mutual 
knowledge about methods and techniques for cross-border identification, freezing, seizure and 
confiscation of illicitly acquired assets.  

1.2. 

Notifications sent by Member States 

Article 8.1 of the Decision requires Member States to transmit to the General Secretariat of 
the Council and to the Commission by 18 December 2008 the text of any provisions of their 
national  law  enabling  them  to  comply  with  the  obligations  imposed  on  them  under  this 
Decision. 

The Commission received notifications from the following 21 Member States: AT, BE, BG, 
CY, CZ, DE, DK, EE, EL, FI, FR, HU, IE, LT, LU, LV, NL, PL, SK, SV and UK.  

ES did not send its notification to the Commission, but notified the General Secretariat of the 
Council.  

No notification was received from MT, IT, PT, RO and SI. 

Most  of  the  notifications  sent  by  the  Member  States  simply  indicate  the  details  of  their 
designated  ARO  or  AROs  (the  Decision  allows  Member  States  to  designate  a  second 
authority as ARO if they so wish) and, in some cases, a reference to the applicable national 
provisions.  The  notifications  of  BE,  EL  and  IE  also  include  the  full  text  of  the  relevant 
national provisions.  

1 
2 

OJ L 332 of 18.12.2007, p. 103. 
OJ L 386 of 29.12.2006, p. 89. 

EN 

2 

   EN 

 
                                                 
1.3.  Method and evaluation criteria 

Article 8(3) of the Decision provides for the establishment of a Commission written report on 
the Member States’ compliance with this Decision by 18 December 2010.  

Only eight Member States sent their notification by the time of the original deadline set by the 
Decision.  Moreover,  most  Member  States’  notifications  covered  only  one  aspect  of  the 
Decision,  i.e.  the  implementation  of  the  provisions  on  the  designation  of  AROs  (Article  1). 
The  notifications  sent  did  not  mention  the  implementation  of  the  provisions  on  cooperation 
between AROs (Article 2), exchange of information between AROs on request (Article 3) and 
spontaneously (Article 4), compliance with data protection rules (Article 5), and exchange of 
best practices between AROs (Article 6).  

It was therefore necessary to combine the official notifications with other information if only 
in order to cover the implementation of the minimal legal provisions in the Decision.  

Information  on  the  implementation  of  these  provisions,  as  well  as  on  the  Member  States’ 
progress  in  designating  AROs,  has  been  gathered  at  the  meetings  of  the  informal  EU  Asset 
Recovery  Offices’  Platform  (“ARO  Platform”).  This  platform  has  met  regularly  since  the 
beginning of 2009 and includes the designated AROs in the Member States and the authorities 
involved in setting up an ARO or temporarily acting as an ARO. 

In  particular,  at  the  ARO  Platform  meetings  held  in  March  and  May  2010,  the  AROs 
indicated  to  the  Commission  their  preference  for  an  implementation  report  with  a  broader 
scope  than  the  provisions  of  the  Decision  and  which  also  covered  aspects  of  the  structure, 
powers  and  access  to  information  of  the  designated  AROs,  the  progress  towards  a  secure 
information exchange system and the main challenges that AROs are facing.  

The above information was gathered from a table providing basic information on designated 
AROs  (ARO  Matrix)  and  from  the  replies  of  the  AROs  to  a  short  additional  questionnaire 
distributed by the Commission (17 AROs replied to the questionnaire between September and 
November 2010). It was further supplemented by information from the proceedings of a pan-
European Conference on Asset Recovery Offices held in Brussels on 6-7 December 2010. 

2. 

EVALUATION 

Article 1 – Asset Recovery Offices  

The following AROs were designated according to Article 8.1 of the Decision:  

Austria  designated 
"Vermögensabhöpfung"). 

the  Federal  Criminal  Police 

(Bundeskriminalamt  –  Referat 

Belgium designated the Organe Central pour la Saisie et la Confiscation (Central Office for 
Seizure and Confiscation – COSC), established by the law of 26 March 2003. 

Bulgaria  designated  two  AROs,  the  Commission  for  Establishing  Property  from  Criminal 
Activity  (CEPACA,  which  subsequently  changed  its  name  to  CEPAIA),  and  the  Supreme 
Prosecutor's office.  

Cyprus designated the Unit for Combating Money Laundering (MOKAS-FIU Cyprus).  

EN 

3 

   EN 

 
The  Czech  Republic  designated  the  Unit  Combating  Corruption  and  Financial  Crimes 
(UOKFK), International Cooperation Department, and enacted Act no. 273/2008. 

Denmark  designated  the  State  Prosecutor  for  Serious  Economic  Crime  (Statsadvokaten  for 
Særlig Økonomisk Kriminalitet)  

Estonia designated the V Division, Investigation Department, Central Criminal Police  

Finland  designated 
Division/Communications Centre 

the  National  Bureau  of 

Investigation,  Criminal 

Intelligence 

France  designated 
the  Central  Directorate  for  Criminal  Investigations  (Plateforme 
d'Identification des Avoirs Criminels - PIAC). France recently designated another ARO, the 
Agency  for  the  management  and  recovery  of  the  assets  seized  and  confiscated  (AGRASC). 
The notification to the Commission is under way.  

Germany designated two AROs, the Federal Criminal Police (Bundeskriminalamt Referat SO 
35 "Vermögensabschöpfung") and the Ministry of Justice (Bundesamt für Justiz) 

Greece  designated  the  Financial  and  Economic  Crime  Unit  within  the  Ministry  of  Finance, 
according to law no. 3842/2010. 

Hungary designated the National Investigation Office (Nemzeti Nyomozó Iroda). 

Ireland  designated  the  Criminal  Assets  Bureau,  established  by  the  Criminal  Assets  Bureau 
Act of 2005. 

Latvia  designated  the  Economic  Police  Department  of  the  Central  Criminal  Police 
Department of the State Police. 

Lithuania designated two AROs, the Criminal Police (Lietuvos kriminalines policijos biuras) 
and the General Prosecutor Office (Lietuvos Respublikos generaline prokuratura)  

Luxembourg designated the Parquet du Tribunal d'Arrondissement de Luxembourg, Section 
éco-fin. 

The  Netherlands  designated  the  Criminal  Assets  Deprivation  Bureau  Public  Prosecution 
Service (Bureau Ontnemingswetgeving Openbaar Ministerie - BOOM). 

Poland  designated  the  Assets  Recovery  Unit,  Criminal  Bureau,  General  Headquarters  of 
Police. 

Slovakia  designated  the  Financial  Intelligence  Unit  of  the  Bureau  of  Combating  Organised 
Crime of the Presidium of the Police Force. 

Spain designated two AROs: the Intelligence Centre against Organised Crime (CICO) and the 
Anti-drugs  Special  Prosecution  Office  (Fiscalia  Especial  Antidrogas)  at  the  Ministry  Of 
Justice.  

Sweden  designated  two  AROs:  the  National  Criminal  Intelligence  Police  Service  and  the 
National Economic Crimes Bureau (Ekobrottsmyndigheten). 

EN 

4 

   EN 

 
The United Kingdom designated two AROs: the Serious Organised Crime Agency (SOCA) 
for  England,  Wales  and  Northern  Ireland  and  the  Scottish  Crime  and  Drug  Enforcement 
Agency (SCDEA) for Scotland. 

The remaining Member States provided the following information on their progress towards 
designation of an ARO: 

Malta indicated that the National Fraud Squad will be designated as the National ARO. 

Portugal indicated that a group appointed under the authority of the Minister of Justice has 
been given the task of establishing the structure of the future ARO. 

Romania indicated that an ARO would be established under the responsibility of the Ministry 
of Justice. The ARO would be multidisciplinary and involve the law enforcement structures 
that have temporarily acted as the ARO. The relevant personnel, including the CARIN contact 
point, would be detached to the future ARO.  

Slovenia  indicated  that  consideration  is  being  given  to  establishing  an  ARO  under  the 
responsibility of the Public Prosecution Office.  

Italy  indicated  that  consideration  is  being  given  to  establishing  an  ARO  under  the 
responsibility of the Ministry of Interior. The relevant provisions for internal designation are 
being drafted. 

So far, seven Member States (BG, DE, ES, FR, LT, SV, UK) have taken advantage of the 
possibility  offered  by  Article  1(2)  to  designate  two  AROs.  Therefore  there  are  currently  28 
designated AROs in the EU. 

The  AROs  designated  so  far  are  primarily  established  within  the  law  enforcement  services. 
The  remainder  are  divided  almost  equally  between  judicial  AROs  and  AROs  having  a 
multidisciplinary structure. 

As the Decision is also seeking to establish formal structures to support the activities of the 
CARIN  Network,  it  is  important  to  note  that  almost  all  the  designated  AROs  include  the 
CARIN contact point(s)3.  

Article 2 – Cooperation between Asset Recovery Offices  

This  Article  requires  Member  States  to  ensure  that  AROs  cooperate  with  each  other  in 
facilitating the tracing and identification of proceeds of crime and other crime related assets 
by  exchanging  information  and  best  practices,  both  upon  request  and  spontaneously.  The 
exchange  of  information  and  best  practices  between  AROs  should  take  place  regardless  of 
their status (administrative, law enforcement or judicial authority). 

During  the  discussions  in  the  ARO  Platform  meetings,  AROs  have  generally  expressed 
satisfaction with the degree of cooperation and exchange of best practices with other AROs.  

3 

CARIN  foresees  two operational  contact  points (one  law  enforcement,  one  judicial)  per  country. It  is 
supported by the Commission and by Europol (hosting its permanent Secretariat) and includes experts 
from over 50 countries and jurisdictions, including 26 EU Member States. 

EN 

5 

   EN 

 
                                                 
There were no reports of any ARO being refused cooperation by another ARO on the grounds 
of its status. 

It  can  therefore  be  concluded  that  the  provisions  of  this  Article  are  being  generally 
implemented. 

Article 3 - Exchange of information between Asset Recovery Offices on request  

This  Article  explains  that  the  requests  for  information  sent between  AROs  are  regulated  by 
the  Swedish  Initiative  and  its  implementing  rules.  The  Swedish  Initiative  introduced  time 
limits  to  reply  to  requests  for  exchange  of  information  between  law  enforcement  services 
within  the  framework  of  a  criminal  investigation  or  criminal  intelligence  operation,  as 
follows: 

Eight  hours  for  urgent  requests  for  information  and  intelligence  regarding  serious  offences4 
when the requested information or intelligence is held in a database that is directly accessible 
by a law enforcement authority  

One week for non-urgent requests for information and intelligence regarding serious offences 
when the requested information or intelligence is held in a database that is directly accessible 
by a law enforcement authority. 

Two weeks in all other cases (database not directly accessible and/or request not related to a 
serious crime). 

These  stringent  time  limits  are  applicable  provided  that  the  requesting  authority  includes  a 
number of items of information in the Swedish Initiative request form (subject of and reasons 
for the request, nature of the proceedings, details concerning the property targeted or sought 
and  concerning  persons  presumed  to  be  involved)  as  precisely  as  possible.  Moreover,  in  all 
the above cases there is the possibility of postponement. 

The designated AROs indicated that they are generally able to meet the above deadlines. In 
particular, AT, CZ, DE, ES (one ARO), HU, LT and NL replied affirmatively. BE and ES 
(the other ARO) can meet them most of the time; in CY it depends on the type of information 
requested. LV may not be able to meet the 8-hour time limit (this ARO does not work 24/7), 
while  IE  indicated  that  they  cannot  always  meet  the  deadlines  as  the  quality  of  the 
information supplied by other AROs often requires further checks. 

Article 3(2) of the Decision makes reference to the information exchange form annexed to the 
Swedish Initiative and refers to it as a mandatory element. During the discussions in the ARO 
Platform  on  this  point,  the  Council  Secretariat  reported  that,  under  the  implementing 
guidelines  of  the  Swedish  Initiative,  Member  States  agreed  that  the  form  should  not  be 
considered as mandatory.  

Nevertheless, most AROs (at least those in AT, BE, BG, CY, CZ, DE, EE, ES, HU, IE, LT, 
LV,  NL)  actually  use  the  Swedish  Initiative  form  when  sending  requests  to  other  AROs, 
although sometimes in conjunction with other tools5.  

4 

Such as the offences covered by Article 2(2) of Framework Decision 2002/584/JHA on the European 
Arrest Warrant. 

EN 

6 

   EN 

 
                                                 
AROs send information requests to other AROs, but many of them also use other channels, 
such as CARIN (BE, DE, ES, NL), the Interpol liaison officers (AT, CZ, DE, ES), Europol 
(CZ,  ES),  the  liaison  officers  network  of  national  law  enforcement  agencies  (AT,  CZ,  DE, 
ES, HU, NL), their national Financial Intelligence Unit (EL, LT) or the liaison officers of the 
Southeast European Cooperative Initiative (HU). The majority of AROs (at least those in AT, 
BE,  CY,  CZ,  DE,  EE,  ES,  HU,  IE,  LV,  NL)  keep  statistics  on  their  exchanges  of 
information  with  other  AROs.  However,  there  are  substantial  differences  between  the 
categories and indicators used. The possible introduction of a more secure system to exchange 
information would facilitate the collection of data for statistical purposes. 

Notwithstanding  the  relative  lack  of  comparable  data,  the  discussions  in  the  ARO  Platform 
have shown that, since the adoption of the Decision, the number of requests made by AROs to 
other AROs has increased substantially and the quality of the replies has generally improved. 

The  opinions  of  the  AROs  on  the  quality  of  the  replies  they  received  vary  considerably. 
According  to  some  (AT,  CZ)  the  information  received  was  very  good,  for  others  (BE,  EE, 
LV) it was good, for others (DE, ES, HU, IE, LT) it was fairly basic (although sufficient to 
start an investigation). 

Many  AROs  underlined  in  their  contributions,  and  at  the  ARO  Platform  meetings,  the 
importance of providing better information when sending a request.  

As the time limits in the Swedish initiative are observed  in general, its  form  is  widely  used 
and the quality of the replies is at least sufficient, it can be considered that the provisions of 
this Article are being implemented. 

Article 4 – Spontaneous exchange of information between Asset Recovery Offices  

This Article provides for an ARO to send information to another ARO without a prior request.  

The  discussions  with  ARO  practitioners  indicate  that  there  are  some  cases  of  spontaneous 
exchange  (for  example  between  BE  and  NL),  but  no  statistics  have  been  provided  on  their 
frequency.  The  available  information  does  not  shed  enough  light  on  the  implementation  of 
this Article. 

Article 5 – Data protection 

The data gathered do not point to any violations of the applicable data protection provisions, 
having regard to Framework Decision 20086.  

Notwithstanding  the  differences  in  national  data  protection  laws  and  practices,  the  system 
envisaged (the applicable data protection provisions are those of the receiving ARO) does not 
seem to significantly affect the possibility of sending or receiving information. In fact, most 

5 

6 

Such  as  email  for  simple  requests  or  the  form  used  by  the  CARIN  contact  points  to  exchange 
information. 
Having regard to the provisions in the Decision on the use of the data by the receiving Member State, 
the applicable rules should be those of Framework Decision 2008/977/JHA of 27 November 2008 on 
the  protection  of  personal  data  processed  in  the  framework  of  police  and  judicial  cooperation  in 
criminal  matters,  OJ  L  350  of  30.12.2008,  p.  60.  There  is  no  such  reference  because  the  Framework 
Decision was adopted one year after the adoption of the Decision.  

EN 

7 

   EN 

 
                                                                                                                                                         
of the AROs indicated that the existing rules on data protection do not impact on the exchange 
of information with other AROs.  

Article 6 - Exchange of best practices 

According  to  this  Article,  AROs  should  exchange  best  practices  on  how  to  improve  the 
effectiveness of their asset tracing efforts.  

Several examples of best practice have been identified by the AROs based on their experience 
with  other  AROs.  Many  of  them  relate  to  the  application  of  the  CARIN  recommendations 
(which themselves established best practices). Some relate to cooperation on asset tracing in 
specific bilateral cases and some also cover operational activities not related to the tracing of 
assets (e.g. further law enforcement support after the assets have been identified). Feedback 
from  the  cooperation  between  AROs  is  generally  positive.  Some  of  these  practices  are 
regularly exchanged at the meetings of the EU informal ARO Platform. 

Article 7 - Relationship to existing arrangements for cooperation  

This provision does not require transposition.  

3. 

MAIN CHALLENGES FOR THE AROS 

In  order  to  understand  the  main  challenges  that  AROs  face,  the  following  features  of  the 
designated ARO should be kept in mind: 

•  The  majority  of  the  AROs  have  relatively  little  personnel.  Only  six  out  of  28 

designated AROs have 10 or more staff members.  

•  The  key  function  of  the  AROs  is  to  trace  and  identify  assets  on  their  national 
territory.  However,  most  AROs  do  not  have  access  (direct  or  indirect)  to  all 
relevant databases that would allow them to perform their task more effectively. 

•  While  all  AROs  have  access  to  company  registers,  centralised  land  registers  do 
not exist in all Member States. Only one ARO has access to a national register of 
bank accounts, which is found in only five countries.  

•  AROs  exchange  sensitive  information  (e.g.  bank  account  numbers)  by  e-mail  or 
fax  and  do  not  benefit  from  the  support  of  a  fully  secure  information  exchange 
system. 

•  Only  some  AROs  are  central  contact  points  at  national  level  for  the  requests  of 
mutual  legal  assistance  related  to  asset  recovery  sent  by  the  authorities  of  other 
Member States. 

•  Only a few AROs are involved in the management of frozen assets. 

•  About half of the AROs do not have access to judicial statistics on freezing and 

confiscation.  

AROs consider that access to financial information (notably to bank account information) is 
the most important challenge they face. Their second most relevant concern is the lack of a 

EN 

8 

   EN 

 
secure  system  to  exchange  information.  Other  recurrent  challenges  mentioned  by  the  AROs 
are that financial investigators receive little specialized training and, more generally, that they 
lack resources.  

Other challenges mentioned by the AROs include the differences in the national legislation on 
what information can be accessed by AROs, their limited links with the authorities in charge 
of asset management, the lack of an evaluation system for the AROs, the data protection or 
bank secrecy provisions and the fact that registers of bank accounts do not exist in all Member 
States.  

Towards a secure exchange of information system for the AROs 

The  Decision  does  not  specify  the  channels  for  the  operational  cooperation  between  the 
AROs. A key issue identified in the ARO Platform is the need for a more secure means for the 
exchange of operational information between AROs. Currently, sensitive information is often 
exchanged via e-mail, which may pose a certain security risk.  

In  its  Communication  on  the  Proceeds  of  Organised  Crime7,  the  Commission  encourages 
Europol  to  play  a  co-ordinating  role  between  national  Asset  Recovery  Offices.  In  this 
connection the Europol Criminal Assets Bureau (ECAB)8 proposed to explore the possibility 
of  using  the  Europol  SIENA  system9  for  the  purpose  of  bilateral  information  exchange 
between AROs. The proposal was well received by the ARO Platform, where the following 
points were established:  

•  There is a clear need to establish a secure channel for direct information exchange 

between AROs; 

•  SIENA is already operational, providing a technical solution for the exchange of 
law enforcement information, within a sound legal basis using the highest security 
standards;  

•  SIENA  could  represent  a  cost–effective  solution,  as  it  builds  upon  an  existing 
network;  therefore  financial  support  for  the  creation  of  a  new  network  is  not 
required; 

•  If SIENA were chosen for information exchange between AROs, it would need to 
provide for direct bilateral exchange between AROs. Member States would need 
to nominate their AROs as competent authorities within SIENA and the Swedish 
Initiative.  They  would  also  need  to  technically  link  their  AROs  to  their  Europol 
National Units10.  

7 
8 

9 

COM (2008) 766 final of 20.11.2008. 
ECAB  assists  financial  investigators  in  tracing  criminal  proceeds  in  other  countries.  In  2007  it 
supported 133 investigations.  
The Secure Information Exchange Network Application (SIENA) is a new generation communication 
tool 

designed to enable swift, secure and user-friendly exchange of operational and strategic crime related 
information and intelligence between the Member States, Europol and Third Parties with whom Europol has a 
cooperation agreement. 
10 

Which are national central contact points to exchange information with Europol.  

EN 

9 

   EN 

 
                                                 
In  September  2009,  Europol  decided  to  run  a  pilot  phase  in  which  interested  AROs  could 
participate. AROs from 11 countries (BG, DK, EE, ES, FR, HU, NL PL, SK, SV and UK) 
agreed to test SIENA for the information exchange between AROs.  

In July 2010, eight ARO staff members (from BG, DK, EE, HU, NL, PL and UK) received 
SIENA training at the Europol Headquarters. The Pilot Phase started in July and ran until the 
end of September 2010. This pilot is currently under assessment.  

If successful in 2011, the first AROs could officially link to SIENA. Efforts to link AROs to 
SIENA will continue, with the aim of connecting the majority of AROs. 

4. 

CONCLUSIONS 

As the core provisions of the Decision relate to the establishment or designation of the AROs 
and  to  their  exchange  of  information,  the  degree  of  implementation  of  the  Decision  in  the 
Member  States  can  be  considered  as  moderately  satisfactory.  Twenty-two  Member  States 
have AROs in place and notified the Commission (at least informally) by the end December 
2010, two years after the deadline set by the Decision. 

The Commission Communication "An Internal Security Strategy in action"11 calls on Member 
States to establish, by 2014, AROs that are equipped with the necessary resources, powers and 
training, and the ability to exchange information, and it states that by 2013 the Commission 
will  develop  common  indicators  against  which  Member  States  should  evaluate  the 
performance of the AROs. 

Initial proposals on effectiveness indicators that could apply to AROs were put forward at the 
pan-European  Conference  on  AROs  in  December  2010.  It  was  also  proposed  to  regularly 
assess the effectiveness of AROs (through compliance with the indicators) by way of informal 
visits by peer experts, followed by discussions in the ARO Platform.  

At  the  same  time,  amendments  to  the  existing  legal  framework  on  confiscation  are  being 
envisaged. In the Communication "An Internal Security Strategy in action" the Commission 
announced its intention to propose legislation in 2011 to strengthen the EU legal framework 
on confiscation12. This Decision, which establishes the legal framework for the exchange of 
information  between  AROs,  does  not  seem  to  present  any  relevant  shortcomings.  However, 
the  new  legislation  offers  the  Commission,  the  European  Parliament  and  the  Council  a 
window  of  opportunity  to  introduce  new  provisions  aimed  at  enhancing  the  powers  of  the 
AROs or their capacity to access information, as appropriate.  

The Commission invites all Member States to consider this Report and to provide all further 
relevant  information  to  the  Commission  and  to  the  Council  Secretariat,  in  accordance  with 
Article 8 of the Decision.  

11 
12 

COM (2010) 673 of 22.11.2010. 
In particular in order to allow more third-party confiscation and extended confiscation and to facilitate 
mutual recognition of non-conviction-based confiscation orders between Member States. 

EN 

10 

   EN 

 
                                                 
Five Member States have not yet designated their ARO. As any network is only as strong as its 
weakest  link,  this  may  substantively  hamper  the  Member  States'  capacity  to  trace  illicitly 
acquired assets across the European Union. The Commission expects all those Member States 
which have not yet implemented this Decision to do so without delay. 

EN 

11 

   EN