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Policy

GUIDING PRINCIPLES 





At LARMO, our mission is centered around promoting effective policies through collaboration with local and global partners, as well as subject matter experts. We firmly believe that a robust policy framework should not only represent excellence but also offer pragmatic solutions for everyday use. Our approach entails aligning policies with legal frameworks, maintaining adaptability across diverse scenarios, and anchoring them in our core principles and values.


The set of policies established by LARMO is thoughtfully designed to seamlessly complement one another, collectively constituting a repository of invaluable insights and best practices. This resource is dedicated to empowering our dedicated staff and their respective departments, nurturing a culture of informed decision-making.


Outlined below are select illustrations of policies currently under development at LARMO. We continually refine and enhance these policies through an interactive process, drawing upon hands-on experience and insights gathered from various stakeholders:
        
        
        

                
                
            
        
    


                
            
        
    


                                
                
            
        
    




    
        
        
        
            
                                
                
                    



    
        
            
            
            
                
                    


    
        
            
                
            
            
                                                
                
                    

        
                
                        Transparency and Accountability                    
        
        
    
        
        
                








At LARMO, we recognize that transparency forms the foundation of thriving organizations. While certain aspects of our operations demand confidentiality to safeguard whistleblowers and uphold legal integrity, we uphold the principle that transparency stands as a paramount goal where confidentiality isn’t essential.


Our organization’s belief is that information and data pertinent to LARMO’s functions should be readily accessible in a concise and comprehensible manner. To this end, we have instituted robust protocols that guide LARMO’s offices and personnel to systematically document decisions, information, and relevant materials. This ensures that non-confidential information is consistently and transparently disseminated, with regularity, to both the general public and the media, as appropriate.


LARMO diligently adheres to all pertinent legal frameworks that uphold data transparency and the right to access information. We meticulously index and categorize data and documents, boosted by clear and streamlined procedures, thereby ensuring that information is promptly furnished upon request. Simultaneously, we remain committed to maintaining the confidentiality of information vital to the nature of LARMO’s responsibilities.


By upholding these principles, we affirm our dedication to cultivating trust, fostering open communication, and advancing the broader goals of our organization.
        
        
        

                
                
            
        
    


                
            
        
    




    
        
            
            
            
                
                    


    
        
            
                
            
            
                                                
                
                    

        
                
                        Corporate Governance Policy                    
        
        
    
        
        
                
LARMO’s Corporate Governance Policy upholds the highest standards of responsible management, ethics, and decision-making. We prioritize transparency, accountability, and integrity throughout our operations. Our Board of Directors, composed of diverse experts locally and internationally, ensures strategic well-roundedness, while our Executive Leadership Team upholds our core values and guides ethical conduct. Employees follow a comprehensive Code of Conduct emphasizing honesty and integrity, with policies in place to manage conflicts of interest. Financial oversight and resource allocation procedures are transparent, supporting asset recovery and growth. Collaborative relationships with authorities and transparent stakeholder communication enhance accountability. Comprehensive risk assessment and adherence to laws and ethical standards ensure stability and legality. Performance evaluations and transparent reporting maintain accountability and integrity.




This policy drives our commitment to ethical, legal, and effective operations, reinforcing our dedication to responsible asset recovery and management and collaboration while promoting justice ensuring that our actions are aligned with our mission to recover assets and promote justice for Libyan peoples.


 


 
        
        
        

                
                
            
        
    


                
            
        
    


                                
                
            
        
    




        
    
        
        
        
            
                                
                
                    



    
        
            
            
            
                
                    


    
        
            
                
            
            
                
                
                    

        
                
                        Asset Recovery Policy                    
        
        
    
        
        
                




 


At LARMO, our asset recovery policy aligns rigorously with international standards, particularly those outlined by the World Bank’s Stolen Asset Recovery Initiative (StAR). As committed partners of StAR, our procedures reflect an unwavering dedication to transparent, accountable, and ethical asset recovery practices. We collaborate with respected entities like the World Bank Group and UNODC, ensuring global best practices and information exchange.


Our policy emphasizes ethical conduct and transparency at every stage, aiming to prevent safe havens for corruptly acquired Libyan assets. Victim-centered recovery prioritizes justice and equitable restitution. We streamline procedures for efficient asset recovery while continually learning and innovating, staying at the forefront of effective practices.
        
        
        

                
                                                
            
        
    


                
            
        
    




    
        
            
            
            
                
                    


        




    
    




    
        
            
                
            
            
                                

    
                        
        
    
                
                
                    

        
                
                        	Whistle-Blower Policy                     
        
        
    
        
        
                


We are in the process of finalizing a comprehensive whistleblower policy framework that adheres to global best practices. This policy aims to empower individuals to disclose information about hidden stolen Libyan assets, thereby contributing to the identification, tracing, and recovery of assets. In developing this policy, LARMO seeks to create a culture of accountability, transparency, and integrity. By offering a safe and supportive environment for whistleblowers, we aim to strengthen our asset recovery efforts.




The policy establishes clear reporting channels, safeguards whistleblower identities, and provides incentives for credible information. We maintain a safe reporting environment, shield whistleblowers from retaliation, and offer monetary rewards for asset recovery insights. This policy underscores our commitment to transparency, integrity, and accountability, driving effective asset recovery efforts.










        
        
        

                
                
            
        
    


                
            
        
    


                                
                
            
        
        

    




    
        
        
        
            
                                
                
                    



    
        
            
            
            
                
                    
                
            
        
    


                                
                
            
        
    




    
        
        
        
            
                                
                
                    



    
        
            
            
            
                
                    


    
        
            
                
            
            
                                                
                
                    

        
                
                        Asset Management Policy                    
        
        
    
        
        
                






LARMO is dedicated to the responsible and transparent management of recovered assets, aiming to maximize their benefit for the people of Libya. In alignment with international best practices, we are establishing the Asset Management Fund as a credible repository for Libya’s recovered assets. The Fund will be governed by a diverse Board comprising Libyans and international experts, ensuring the highest standards of governance and integrity. The Board ensures proper resource stewardship aligned with Libyan’s welfare and development. It formulates strategic policies, manages risks, allocates resources, and maintains transparency and compliance.


Through this Asset Management Policy, LARMO strives to uphold the principles of responsible governance, transparent management, and sustainable growth. By adhering to these principles, we aim to foster economic development and improve the lives of the people of Libya.






        
        
        

                
                
            
        
    




    
        
            
                
            
            
                
                
                    

        
                
                        Combating Money Laundering and Terrorist Financing Policy                    
        
        
    
        
        
                




In accordance with the UN Vienna 1988 Convention, Article 3.1, which defines money laundering as the act of knowingly converting or transferring property derived from offenses, with the intent to conceal its illicit origin or aid individuals evading legal consequences, LARMO acknowledges its duty to combat these unlawful activities.


In 2022, the Director General of LARMO took decisive action by establishing the Department for Combating Money Laundering and Terrorist Financing. This department is driven by a multi-faceted mandate: to bolster our capacity to prevent and investigate corruption, to foster closer collaboration among Libyan’s governmental departments for streamlined asset tracking, and to enhance our ability to thwart money laundering and conduct thorough investigations.


LARMO stands as an integral component of the National Committee for Combating Money Laundering and Terrorism Financing. Key stakeholders, including the Central Bank of Libya, the Ministry of Finance, the Ministry of Economy, and the Ministry of Interior Affairs, unite under this committee’s umbrella. Together, we are engaged in the development of a comprehensive policy framework that addresses the paramount concerns of battling money laundering and terrorist financing. This policy document encompasses a revitalization of reporting procedures, incorporating advanced data analysis tools for more effective decision-making.


LARMO is dedicated to dismantling the infrastructure that supports money laundering and terrorist financing. By aligning with Libyan’s central institutions, we are ready to create a secure defense against these illicit activities. Our collective efforts will not only protect the integrity of financial systems but also ensure the safety and security of our nation.
        
        
        

                
                                                
            
        
    


                
            
        
    




    
        
            
            
            
                
                    


    
        
            
                
            
            
                                                
                
                    

        
                
                        Fund Distribution Policy                    
        
        
    
        
        
                
The primary mission of the LARMO Fund is to establish a secure and safeguarded repository for recovered Libyan stolen assets. These assets will be utilized to initiate and support economic and social initiatives that will benefit the people of Libya. Our primary goal is to generate sustainable, long-term returns that will ensure prosperity for multiple generations of Libyans. While the Fund’s fundamental purpose is to receive recoveries facilitated by LARMO, protect these assets, and strategically invest them to build robust financial prosperity for Libya’s future, we also recognize the urgent requirements of Libya for funding projects that enhance the quality of life for its citizens.


In light of this recognition, the Fund’s Board will be empowered to authorize distributions from the repository. These distributions will be directed toward financing projects that hold the potential to drive positive social, economic, and humanitarian outcomes in Libya. The decision-making process for such distributions is committed to being well-informed, transparent, and accountable to the people of Libya. All projects with social and economic implications, as proposed or sanctioned by the Fund Board, will adhere to the principles of transparency throughout their tendering procedures. Furthermore, to ensure the highest standards of accountability, these projects will undergo comprehensive auditing.


Our commitment is to serve as responsible stewards of these recovered stolen assets, channeling them toward projects that uplift communities, foster economic growth, and contribute to the overall well-being of Libyan citizens.Top of Form
        
        
        

                
                
            
        
    




    
        
            
                
            
            
                
                
                    

        
                
                        Human Resources Policy                    
        
        
    
                

    
                        
        
    
        
        
                
At LARMO, we recognize that our success in achieving our mandates of asset recovery, asset management, investigations, and combating financial crimes is directly tied to the talent of our team. We are committed to hiring and retaining the best and brightest professionals, both locally and internationally, to ensure the effective fulfillment of our objectives. Our Human Resources Policy outlines our principles and practices to attract, develop, and nurture exceptional talent across various areas, including asset recovery, investigations, legal, financial analysis, forensic accounting, and computer expertise.


Our Human Resources Policy underscores our commitment to nurturing a dynamic and empowered workforce that drives our mission forward. By attracting top talent, fostering their development, and providing an inclusive and supportive environment, we are prepared to make significant advances in asset recovery, asset management, investigations, and the fight against financial crimes.
        
        
        

                
                
            
        
    


                
            
        
    


                                
                
            
        
    




    
        
        
        
            
                                
                
                    



    
        
            
            
            
                
                    
                
            
        
    


                                
                
            
        
    




    
        
        
        
            
                                
                
                    



    
        
            
            
            
                
                    


    
        
            
                
            
            
                                                
                
                    

        
                
                        Conclusion                    
        
        
    
        
        
                
In conclusion, these meticulously crafted policies reflect LARMO’s resolute dedication to the highest standards of integrity, transparency, and ethical conduct. By adhering to these principles, we not only uphold our commitment to responsible governance but also contribute to the betterment of societies and the advancement of justice. As we embark on our journey to recover and manage assets for the benefit of Libyan peoples, combat financial crimes, and promote economic development, these policies serve as our compass, guiding us toward a future where accountability, collaboration, and ethical practice form the basis of every action we undertake. Together, with the invaluable guidance of our stakeholders, partners, and subject matter experts, we are confident in our ability to forge a path that not only aligns with global best practices but also sets new benchmarks for excellence in the areas of asset recovery, management, and ethical conduct.