The announcement of the publication of the balance sheet is the first important decision taken by Ernst von Freyberg, the new president of the IOR Council of Superintendence. Von Freyberg took over on February 18, after a nine-month search for a successor to Ettore Gotti Tedeschi as president of the IOR’s Council, a.k.a. «board of laymen». Von Freyberg has worked with the IOR employees on putting together a balance sheet during these first three months of his presidency. In this period, there has been a change in Popes. However, the Vatican’s agenda on financial issues is still that inaugurated under Benedict XVI’s pontificate. It is a «transparency program» which addresses all Vatican finances, which have been – rightly or wrongly – pervaded by a myth of opacity and lack of international cooperation.

In the Vatican corridors, this myth is called «a misperception». Vatican officials also state that little credit is given to the Vatican for its actions to bring up to international standards the Vatican’s financial system.

Part of this path toward financial transparency was publicly explained by Paolo Cipriani, the IOR’s general manager. In June of last year, featuring an «open doors policy», he met at the Torrione Nicolò V (the IOR headquarters) with ambassadors accredited to the Holy See and a group of journalists. The aim was to correct any possible misperception regarding the Institute’s work.

The meeting took place at a difficult time, on the heels of the IOR’s board of layman adopting a no confidence motion on its president, Ettore Gotti Tedeschi.  Several weeks after, the plenary assembly of MONEYVAL (the Council of Europe committee that evaluates the financial transparency of its member States) was scheduled to evaluate the Holy See’s adherence to anti money laundering international standards.

The debate was particularly polarized around the Vatican anti-money laundering law, which the Holy See substantially and vigorously amended following the first on site visit of MONEYVAL evaluators.  The Vatican adopted a new law on January 25, 2012.

Notwithstanding that the revision of the law had been controversial within the Vatican itself, the MONEYVAL report issued on July, 2012 praised the revision. MONEYVAL noted that the new law «introduced a significant number of necessary and welcome changes.» The same report emphasized that «further important issues still need addressing in order to demonstrate that a fully effective regime has been instituted in practice. » Overall, MONEYVAL evaluators gave high marks to several IOR procedures. Browsing the Report’s Executive Summary, one finds out that the IOR security standards surpass those required by Vatican law (Executive Summary, 39); and that the Vatican legislation on secrecy is considered overall compliant with international standards (paragraph 50). The report also praised the high level of Vatican engagement in international cooperation.

The report also left several issues open. For the past twelve months, the Holy See has been working on a general reform of its financial management and control procedures. The reform is also broader than required by international standards. This is evident in a preview of a Holy See report to MONEYVAL, which volunteers a lot of information about the Vatican’s progress on the implementation of a wide range of anti money laundering recommendations. The Holy See/Vatican City State progress report will be presented in December. By then, a general reform of Vatican finances should have come into effect. Probably, this reform will start in June.

The IOR’ publishing of its balance sheet is thus a part of the Holy See’s long term commitment to transparency. Already, since 1990, an international and independent auditing company (Deloitte in recent years) certifies the Institute’s balance sheet. It is then approved by the Council of Superintendence. The board of laymen must present the balance sheet to the IOR Oversight Cardinals’ Commission by April 30. The cardinals present the balance sheet to the Pope, who then decides, within thirty days, how to allocate the dividend to religious works.

Some data: the IOR has more than 6  billion euro in assets, 33 thousand individual accounts and 25 thousand group-accounts (that is, aggregates of all the accounts of a single religious congregation); 60-65 percent of the IOR’s financial activities are in euros and the rest in dollars; and 5 per cent of the funds are invested in highly-rated investments, which are very secure but do not yield high profits.

In the mean time, the Vatican Authority for Financial Information (AIF) continues to follow a path towards full adherence to international standards. On May 7, it signed a Memorandum of Understanding with its U.S. counterpart, FinCEN (Financial Crimes Enforcement Network). It is the fourth Memorandum of Understanding (MOU) signed by the AIF with fellow Financial Information Units (FIUs). The other MOUs are with the FIUs of Belgium, Spain, and Slovenia.

The news of the memorandum signed with FinCEN is particularly important, considering that in March of 2012, the U.S. Department of State had ranked the Vatican as a “not reliable” State regarding financial transparency.

Next step will be the presentation of the Annual Report of the Authority for Financial Information. René Bruelhart, AIF director, will perhaps do so within this week (on Wednesday).

Greg Burke is an Opus Dei numerary. Even if his career was not carried out under the Opus Dei umbrella, it is also true that Opus Dei has always been very attentive to institutional communications. For a long time, the director of the Holy See Press Office was Joaquin Navarro Valls, an Opus Dei numerary. And, thanks to Navarro Valls’ presence and experience, Opus Dei soon realized that teaching institutional communications to the Church is a must nowadays. The only dissertation paper about the vaticanisti – the journalists specialized in covering the Vatican – came out from the Holy Cross Pontifical University, the Opus Dei University in Rome. And so it was almost logic – even given the good relationships between Georg Gaenswein, secretary of the Pope, and Opus Dei, whose university had Gaenswein as a teacher – to look to Opus Dei to find a solution for the «communication crisis» of the Holy See. It is not by lobbying, but by necessity that Greg Burke, who recently became an Italian citizen and whose native language is English – a much needed value added, since aggressive articles on the Church are often written in English – has been identified as the right person to become the media advisor of the Vatican Secretariat of State.

That something has changed in the Holy See communication strategy is evident. Often, Benedict XVI has personally taken the lead in addressing a situation. We just need to look at how the Vatileaks case was managed, the week following the arrest of Paolo Gabriele, the Pope’s Butler. The statements marking a clear change in the Holy See’s communication strategy followed each other in a crescendo: first, on Tuesday, May 29 morning, Federico Lombardi, director of the Holy See Press Office, asked journalists not to allow themselves to be manipulated, since many of the stories that had been published in the newspapers fell «outside reality»; on Tuesday, May 29 afternoon,  Angelo Becciu – substitute (deputy) to the Secretary of State – gave an interview to the Holy See  newspaper L’Osservatore Romano, asking journalists to reach «a higher moral standard», and criticizing partisan narratives of events; finally, on Wednesday, May 30 morning, for the first time, the Pope talked openly and clearly about the Vatileaks scandal, renewing his trust on his closest collaborators.

It was not the only change. After Paolo Gabriele’s arrest, Lombardi gave a press briefing almost daily, providing updates and setting the record straight on false stories circulating in the media. And there was more. After the IOR (the Vatican’s financial body) board of Superintendence’s no confidence vote on the board’s president, Ettore Gotti Tedeschi, the memorandum of the meeting when the vote took place was “institutionally” leaked to the press. The IOR has maintained, for some time now, an open door policy, allowing an inside look of its work. Not long  ago, a group of ambassadors accredited to the Holy See were invited to a briefing in the Torrione Niccolò V – the IOR’s headquarters – where Paolo Cipriani, general manager, talked about transparency and the activities of the Institute. Last week, it was the turn for a selected group journalists. Standing before them, Cipriani not only outlined the activities of the Institute, but also gave an in-depth explanation about the seizure of 23 million euro transferred by the IOR from an IOR account to Credito Artigiano in 2009 and to the closing of an IOR account in a  JP Morgan branch in Milan in 2012. Cipriani also denied there was a lack of cooperation with the Italian authorities, showing a letter of the Italian police where they thanked the IOR for the speed and precision of responses to their questions – Mondayvatican had already reported about this letter some postings ago.

Even though many inside and outside the Vatican are contemptuous, Benedict XVI is moving on his path toward transparency. This Pope was not afraid to write an open letter to the bishops in the midst of the Williamson affair; to write a letter to the Catholics of Ireland in the midst of the pedophilia scandal; to personally meet the victims of priest abuses, whenever he went to visit a country where there were victims who asked for a meeting; and to start a purification process within the Church that is perhaps poorly explained, though it is true and alive.  Here, the contrast with the “Communication machine” of Joaquin Navarro Valls is most evident. In his more than twenty years as the head of the press office, Navarro proved himself to be much more than a simple means of communication. He was a spin doctor, an editor, a PR man, an investigator, an advisor, a diplomat and an ambassador for the pope.

Is yet to be seen if Greg Burke will be able to have Navarro Valls’ relation with, and influence over, the Papal apartment. Surely, working within the Secretariat of State, he will be closer to the power center, and he will should be in a good position to elaborate communication strategies. Will he be in charge of an information office of the Secretariat of State or will he just be an official inside the Apostolic Palace? And what will be the future of the Holy See Press Office? Will the appointment of Greg Burke change its role?

Some insiders predict that the Holy See Press Office will become a sort of “base”, to put into effect Burke’s strategies. The next step could be to link the Press Office to the Pontifical Council of Social Communication. This would lead to more strict accreditation norms and to a new role for the director of the Press Office: the role of a simple spokesperson.

Though his appointment has still not been officially announced (and it will probably not be, since it is just the hiring of an employee joining the Curia), Burke has already given some interviews about his new charge. Burke wants first of all to listen, think and understand what has failed in Vatican communications. From the Regensburg speech to the Vatileaks, passing through the Williamson affair and the annus horribilis (horrible year) of the pedophilia scandals (it was 2010), the institutional communications of the Holy See was always playing catch-up with the news. Now, they want to address the stories as they hit the news.

Lombardi did not succeed in keeping apace with the news, in part because he lacked the privileged relationship his predecessor had with the Papal apartment. It will surely be a hard challenge. Greg Burke loves to compare his post with that of the «media advisor» of the White House. The Holy See, however, is not the White House, and the Apostolic Palace is not the West Wing. There is a very different storyline to tell, deeply anchored in a Church that is 2000 years old. A Church that still seems unable to communicate everything that it stands for and does. For example, the most interesting part of the journalists’ visit to the IOR was when the general manager, Cipriani, spoke about his trips to personally see “the works of religion” all over the world: «I recently went to Peru – he said – and I found priests that were taking care of people in shanty towns made of mud. The Church does wonderful things all over the world, and to see what the Institute funds help to achieve gave me a better sense of my own job». This part of the story was not covered in the media. That is why Greg Burke’s has such a formidable challenge before him.

After the no confidence vote. The words of Gotti Tedeschi

After receiving a no confidence vote by the IOR Board of Superintendence, Ettore Gotti Tedeschi became part of the investigation on the Italian defense company Finmeccanica. He is not charged with any crime, but he is suspected to have stored documents of Finmeccanica CEO Fernando Orsi. As Gotti Tedeschi, Orsi hails from Piacenza. They are long-time friends. That is why Gotti Tedeschi’s house in Piacenza and his office in Milan were searched. The police took 47 folders, that are said to contain Gotti Tedeschi’s private documents – and not IOR correspondence. These folders are now in the hands of the Public Prosecutor of Naples investigating Finmenccanica. The Public Prosecutor of Naples sent to the Public Prosecutor of Rome some of the documents. The Public Prosecutor of Rome is still investigating 23 million euro transferred by the IOR in September 2010 (20 million were transferred from a IOR account to a branch of Credito Artigiano and 3 million from a IOR account to Banco del Fucino toward a IOR account to a JpMorgan branch in Frankfurt). Gotti Tedeschi has been questioned by both Public Prosecutors. On the one hand – according to the press – he said he wanted to be discreet and not to speak about the IOR in order not to cause pain to the Pope (he insistently has asked for a private audience with Benedict XVI); on the other hand, he reportedly said that there had been opposition to him for his commitment to transparency, his desire not to have any more cipher accounts in the IOR, and his work to add the IOR to the list of virtuous banks compiled and monitored by the Bank of Italy.  On this, he would have had the collaboration of Anna Maria Tarantola, then number two of the vigilance in the Bank of Italy and now general manager-elect of Italy’s public broadcaster, RAI Television.

IOR transparency

These allegations  are a strong blow to the IOR image. But they are not true. One telling conversation – that is in some ways confirmed from what Paolo Cipriani, IOR general manager, recently told in an interview – even if no one will ever officially confirm it, offers insights.  When Ettore Gotti Tedeschi was still the president of the Institute, Paolo Cipriani, the IOR general manager, asked Gotti Tedeschi to show him where the cipher accounts were, since Tedeschi had been repeatedly calling for their closing. Gotti Tedeschi, angry, did not want to identify which accounts he was talking about and said: «There are such accounts, the Bank of Italy told me about them». Cipriani explained the IOR security and transparency procedures in an interview to the Italian newspaper Corriere della Sera. The policy of the Institute changed in 2002, when the KYC procedures was first and scrupulously applied. KYC stands for «know your customer», and involves a thorough screening of customers.

The IOR has always maintained informal but close cooperation with the Guardia di Finanza, i.e. the Italian financial police. The cooperation is so strong that it is told that Paolo Cipriani once got a letter from the Guardia di Finanza, thanking him for the expediency and the precision of his information in response whenever Guardia de Finanza asked for anything. This was a relationship based on trust.  But the handling of the IOR. account at the JP Morgan branch in Milan did not follow this pattern.

The news of the closing of the account was made public the day after the press release of the second on-site visit to the Vatican of the MONEYVAL advisors. The press release acknowledged the steps forward taken by the Holy See.

Il Sole24Ore – the Italian newspaper that spread the news – claimed that the account was closed because the IOR was «unable to answer» requests for further information regarding some payments of the account to the branch of Milan – a peculiar account, which balance was brought to zero at the end of every day. JPMorgan also recalled that the bank activities of the branch are subject «both to the law of the Italian State and to internal regulations». That is why – after looking atthe IOR needs and the requirements imposed by Italian law and bank regulations – JPMorgan reportedly did not think it had enough information to offer pay and cash services to the 1365 account. However, in fact, it was the IOR that closed the account. The decision to close it was in part also a response to the way in which Italian magistrates had asked for information about the account.

FIUs’ – Financial Intelligence Units –purpose is the exchange of internal information. When there is suspicion of money laundering, the bank alerts the vigilance of the Central Bank, which then alerts its financial intelligence unit. The alerts are kept anonymous, to protect the way that the systemprevents money laundering. These parameters are designed by the Egmont Group of Financial Intelligence Units, a «working group» of FIUs to improve cooperation in combating money laundering and the financing of terrorism, and to help develop each State’s programs against money laundering.

The confidentiality of information is a key element in efforts to combat money laundering, as is also stated in Italy in the law 231/2007, that deals with the competences of the Bank of Italy. Art. 6 of the law says that «the FIU carries its functions with full autonomy and independence. To implement these principles, the Bank of Italy regulates the organization and the functioning of the FIU, including the confidentiality of the information collected. The Bank of Italy provides the FIU with financial means and other adequate resources to insure the efficient pursuit of its institutional goals».

In the case of the closing of the JPMorgan account, none of the standard procedures were followed: the Rome’s Public Prosecutor directly alerted the FIU of the Bank of Italy; the FIU then alerted the vigilance of the Bank of Italy; and the vigilance asked the JPMorgan branch information on the account. But, if the public prosecutors want to investigate an account, they must do it through the Guardia di Finaza. Yet, Ettore Gotti Tedeschi maintained that there were valid reasons why  JPMorgan closed the IOR account of its Milan branch. Gotti Tedeschi’s lack of initiative to defend the Institute was noticed by the IOR Board of Superintendence in the now famous meeting of May, 24, when the board passed the no confidence resolution on its president.

The 24 May board of Superintendence

Usually, the meeting of the Council of Superintendence – called on trimestral basis – are divided in two parts: during the first part – that lasts about half an hour – the members of the Board meet; only after – and this is the second part – Paolo Cipriani, general manager of the Institute, enters, and reports on technical aspects and bank operations of the previous semester.

On May 24, Cipriani had to wait two and a half hours. When he was called by the board, Ettore Gotti Tedeschi had already left the meeting, and the no confidence vote had already taken place. The memorandum was already drafted by Carl A. Anderson, who was the secretary of the Board.

Gotti Tedeschi – as written in the memorandum – began the meeting, and spoke for about 70 minutes. After his speech, the members of the board raised some issues. They remarked to the president his unjustified absence to the last two scheduled meetings of the board (on February, 24 and April, 17). The absence to the last meeting was very disappointing: it was the meeting when the board approved the balances and the earnings to be allocated to the Pope. The IOR, in fact, is not a bank, and its fund are at the Papal disposal. Rumors says that Gotti Tedeschi was in Rome, and he was invited to join the meeting. He did not go.

The board also raised with Gotti Tedeschi news leaks. Among the several documents of the institute leaked to the press in the previous months, there was an e-mail sent by Francesco De Pasquale (general manager of the Authority for Financial Information, so formally a controller) to Ettore Gotti Tedeschi (formally, one of the ones controlled) that complained about the ramifications of the Vatican anti-money laundering law – the law n. 127.  The law had been amended as per MONEYVAL recommendations, and this had sparked a lively debate inside the Vatican.   The e-mail – the members of the board noticed – could have only been leaked by Ettore Gotti Tedeschi’s office.

Last key issue, the closing of the JPMorgan account: why did the president not defend the Institute from the attacks and the inaccuracies of the press? It was then that Gotti Tedeschi, angry, abandoned the meeting. It was – for the members of the board – the climax of a tense and overdue situation. In order to manage thecontroversy,it was decided to publicly release the memorandum of the meeting.

On May, 25 – the day after the no confidence motion– the IOR Commission of Cardinals was convoked to decide how to manage the new situation. Only Card. Odilo Scherer could not be part of the meeting, while Card. Telesphore Toppo arrived right in time from India. In that meeting, the cardinals decided how would Gotti Tedeschi be let go from the institute.

What will follow

While awaiting how the investigation would proceed, and as soon as the news of the «memorandum» of Gotti Tedeschi spread, the Holy See released a press communiqué in which it maintained that it trusted that «the prerogatives acknowledged to the Holy See by the international legal order are being adequately considered and respected by the Italian judicial authorities». It is a clear statement: the Holy See reminds all that those are documents from a sovereign country, seized from an ex president of a «body of State».

To think that this would be of detriment to the evaluation of the Holy See Transparency by the Council of Europe would be wrong. It seems MONEYVAL evaluated the IOR «largely compliant» with international standards.  It was just part of the evaluation. The evaluation is not just about the IOR.  It includes the 120 Vatican bodies that deals with budgets and financial transfers.

Holy See financial transparency. Risks and procedures.

It is worth to clarify some assertions made in the last few days. These assertions had partially come out from the same environment that defended Ettore Gotti Tedeschi. They claim that the Holy See risks not to be added to the white list of the virtuous States in terms of prevention of money laundering; the Holy See has been selected to undergo MONEYVAL inspections; and that the Holy See does not want to cooperate with Italian authorities. But these statements are false or grossly inaccurate. It is thus worthwhile to be  very thorough, and explain everything step by step.

White list

Let us begin with the so-called «white list» issue. MONEYVAL – the body of the Council of Europe that evaluates the adherence to the anti-money laundering norms of Council of Europe State members – does not have a white list. MONEYVAL is a body where peer-to-peer evaluations of member States takes place. There are no inspections. There are processes of mutual evaluation. And these evaluations are part of an on-going process. After the plenary assembly of MONEYVAL – 2-6 of July – the report about the Holy See will be public. The draft of this report was first discussed in Strasbourg, during the meeting between Holy See officials and MONEYVAL evaluators in May. Some weaknesseshave been noted. But these weaknesses often deal with the fact that the Holy See is a peculiar State. MONEYVAL reports are divided in three parts: legal, financial and law enforcement. The evaluators rate the adherence to each GAFI recommendation (40+9 until February, now 40, with several novelties). Rating can be: non-compliant, partially compliant, largely compliant or compliant. Of the GAFI recommendations, 16 are «key and core». Of these 16 key and core recommendations, the Holy See – according to the press – would be partially compliant or non-compliant in 8. Obviously, this could change after discussionsat the plenary assembly. If it got 10 negative ratings, the evaluation of the Holy See adherence to international standards would be then assigned to the GAFI International Cooperation Review Group, and so it would take more time to be evaluated largely compliant. There are also infringement procedures on particular ratings. In 2005, Italy was evaluated generally largely compliant. At the same time, there were – in the Mutual Evaluation Report – several non compliant or partially compliant ratings. After two years, the GAFI closed the infringement procedure.

The meetings with the evaluators.

In fact, there is no intention to vote out a State. And the fact that there are 8 points to discuss does not necessarily lead to a general negative rating. The meetings with the MONEYVAL evaluators are characterized by an open discussion. The Holy See could eventually challenge the rating, and explain to the evaluators the reason for some of its peculiarities. The procedure is very well defined in several steps. During the plenary assembly of MONEYVAL, at least one whole day will be dedicated to discuss the draft report about the Holy See/Vatican City State. Three countries must canvass each of the three parts of the report. Then, the assembly as a whole will hold an open discussion. At the end of this discussion, the draft report could be amended. The final decision will be taken by all the delegates that will take part in the plenary assembly in July.

This will not lead directly to the Holy See being added to the white list. There is not a white list that is directly linked to the MONEYVAL evaluation. The white list generally refers to the Common Understanding – i.e. the criteria (defined by the EU. regulation 2005/60/EC) used by EU members about efforts against money laundering. A country is added to this white list only if sponsored by a member State, and only after getting a positive evaluation on its AML/FT (Anti Money Laundering/Financing of Terrorism) policies by an independent and authoritative international body. This white list is not perfect or definitive. For example, the list of virtuous countries published every year by the American Secretary of State follows a different approach. Another aspect of this white list is that States can acknowledge the European white list, and still consider a particular country not trustworthy. For example, Italy has excluded Switzerland from Italy’s white list.

Financial transparency is never ending

Even if MONEYVAL will positively rate the Holy See/Vatican City State, the path to transparency will not stop there. MONEYVAL has already done three evaluation rounds, and at this time some countries are being evaluated for a «follow up round», i.e. a fourth round that – beyond the implementation of specific GAFI recommendations – takes into consideration statistics and effectiveness of the legislation adopted by the member States. The first evaluation round took place in 1998-2000, the second in 2001-2004 and the third in 2005-2009. The Holy See became a MONEYVAL member on April 6^th 2011, and it was promptly admitted to the third evaluation round, that looks at the legislation of a country and the international  standards – for example, if the countries evaluated signed and ratified the Palermo and Wien conventions.

MONEYVAL on site visits to the Vatican

MONEYVAL evaluators went for the first time for an on site visit to the Vatican on November, 21-26. The evaluators assess the legislative situation of the countries incombating money laundering. The result of the visit is reserved to the counterpart: it is a report that shows the key findings of the evaluators and that rates the adherence of the country evaluated to each GAFI recommendation. After the completion of the report, the evaluated country has two months to implement the MONEYVAL recommendations.

On January, 25 2012, with the decree n. 59, the Holy See amended its anti-money laundering law n. 127, following MONEYVAL recommendations, and making it more compliant with international standards. That same day, the Holy See signed and ratified the conventions of New York, Wien and Palermo: this was proof of a long-term commitment to financial transparency. The new law was substantially different from the old one, and outlined a better power distribution. The control of Vatican finances was not exclusively entrusted to the one and only Authority for Financial Information. The amendment of the law was the focus of a strong internal debate, and some – in primis Card. Attilio Nicora, president of the Authority for Financial Information – defined the new law «a step back». In fact, the Holy See followed the MONEYVAL recommendations. Jeffrey Owens, head of tax issues at the Organization for Economic Cooperation and Development, praised the Holy See’s reforms. «The Vatican is heading in the right direction with the revised norms», he said to the Associated Press.

This amendment profoundly changed the Vatican legislative scenario. That is why there was the need for a second on site visit of MONEYVAL evaluators, that took place March 14 to 16 . This visit was not an inspection: it was an assessment of progress. After this second evaluation, the draft report was completed and sent out to the Holy See in April. In May – from the 14th to 16th – a delegation of the Holy See went to Strasbourg to comment on the report and get it ready to be presented to the next plenary assembly. Now, a pre-meeting will probably be held before the plenary assembly of July. And finally, the plenary assembly in July, where a decision will be taken: will the Vatican be subjected to an infringement process? Or will its efforts be awarded? « I have not seen any State – a MONEYVAL evaluator said informally to a Vatican official – going so quickly toward the financial transparency, and making so many changements». These words confirms the Strasbourg appreciation for the Holy See job. Neverthless the difficulties, one could also preview a positive MONEYVAL evaluation. And this would be gained in a very short time.

This is why the Pope steers clear from polemics. Only at the previous general audience, Benedict XVI used the occasion to take a stand against the attacks to his closest collaborators.  At the end of the audience he renewed his trust in them with a precise and straightforward declaration, underlining keywords with his own voice. The latest attacks have been increasingly vague on the Vatileaks issue and the arrest of the butler Paolo Gabriele, and ever more focused on the Works’ Institute (IOR) issue and on the ousting of its former president Gotti Tedeschi.  Tedeschi has been spinning the controversy with his innuendoes, his responses to the magistrates of Rome questioning him as part of an ill-defined investigation, and with the IOR files seized by the Italian public prosecutor of Naples. The Pope responded to all of these  developments, controversies and media attention with a catechesis on a general audience.  As part of the cycle of the catechesis on prayer, the audience was dedicated to prayer in the life of the apostle Paul. The Pope recalls: «Defending the legitimacy of his apostolate, Paul looks up, above all, to his profound closeness to the Lord in prayer, marked by moments of ecstasy, visions and revelations (cf. 2 Cor 12:1ff.). Yet he speaks too of a trial which the Lord sent him lest he become conceited: a mysterious thorn in the flesh (v. 7). Paul therefore willingly boasts of his weakness, in order that the power of Christ might dwell in him (v. 10). Through this experience of mystical prayer, Paul realized that God’s Kingdom comes about not by our own efforts but by the power of God’s grace shining through our poor earthen vessels (cf. 2 Cor 4:7)».

The message of the Pope is that it is not man’s perfection that makes the Church. It is on the contrary the weakness of man that characterizes it. If the Church is still here, it is not because of the men and women that are part of it, but by the grace of God. The call to simply follow the gospel points to a fundamental change coming about under Benedict XVI. The Pope chose his collaborators on the basis of personal knowledge and trust. But their role, the responsibility they are charged with, the «image» they project as Papal collaborators, must not overshadow that of the Church as a whole. In the past, everybody knew Cardinal Angelo Sodano, Secretary of State, while the work of Vatican diplomacy was less known. Now, the Secretary of State, Cardinal Bertone, is receiving a lot of attention, because of  the internal resistance to him and his new course. Yet, Vatican diplomacy is more important than the Secretary of State. At an international level, the Holy See has proposed a World Authority with universal competence. During the Preparatory Commission for a new ATT (Arms Trade Treaty), the Holy See proposed to broaden the ATT to small arms and light weapons, going beyond the seven categories in the U.N. register of arms. The Holy See also supported denying patents to inventions that would damage human beings. Equally important is the Holy See position paper for the Preparatory Commission of the U.N. conference on the environment, Rio+20, where it calls for «a new model of development» and underlined that sustainable development is part of comprehensive human development – one of the key words of the “change of dictionary” for the United Nations, described by Silvano Maria Tomasi, Papal nuncio to the Geneva office of  the United Nations.

Another example of the change of an era is in the profile of the personal secretary of the Pope.  Stanislao Dziwisz – now cardinal and archbishop of Cracow – was in a center stage role.  Georg Gaenswein has been under attack by the leaks, but he has always kept a low profile, fulfilling his duties with discretion.

Many – inside the Vatican – did not welcome this change to a new era.

It is the end of personalism, evident also in the no confidence vote by the “lay” board of the IOR to the president of the board Gotti Tedeschi. He did not get a no confidence vote because of the policy of transparency – that the Holy See is implementing with tenacity and commitment, adhering to international standards – but because the board did not considered him able to lead the institute. His media activism – this is one of the accusations levied against him – was missing when the IOR needed to be defended. The memo of the no confidence vote has been (almost institutionally) released. And the general manager of the IOR, Paolo Cipriani, talked about what the Institute has been doing in terms of transparency during the last years. The facts are public, and there is not much more to say.

The raid

The raid carried was about the investigation on Finmeccanica, an Italian industry specialized in products for defense – Gotti Tedeschi is not under investigation himself, but he could be in possession of papers of Finmeccanica that the CEO of Finmeccanica Fernando Orsi (they’re good friends) consigned him. Even if the investigation on Finmeccanica is not of any particular interest for those who cover the Vatican, it became newsworthy that – among the folders seized by the investigators to Gotti Tedeschi – there was a «memorandum »  that the former president of the I.O.R. was drafting to send to Mons. Georg Gaenswein, secretary of Benedict XVI, so it could be delivered directly to the Pope.

I.O.R. folders?

Gotti Tedeschi  was also reported to keep in his house 47 folders from the I.O.R. Some reports say that the folders would contain information about some I.O.R. accounts – especially of politician, as the ex I.O.R. president would have said -  but the Gotti Tedeschi’s lawyer Palazzo denied it. In the correspondence with some Curial officials, Gotti Tedeschi denounced a «plot» against him. Tedeschi described it as a «Judaic-Masonic »  plot . Tedeschi reportedly thought that : Marco Simeon (33 years old, foreign relations account manager and deputy to the relationship with the institutions of the Italian state television, Rai, and ad interim director of Rai Vaticano,which covers the Holy See) and the lawyer Michele Briamonte (from the office of Franzo Grande Stevens) were part of this plot. Within the Gotti Tedeschi’s sight was also Jeffrey Lena, the Holy See lawyer in the United States who recently has come to live in Rome to work on the reform of Vatican law n. 127 against money laundering, and who is now working along with Vatican officials to prepare the documentation for the July 4^thplenary assembly of MONEYVAL – the body of the Council of Europe that evaluates the adherence to the anti-money laundering norms of Council of Europe State members. MONEYVAL advisors will present their report about Holy See compliance to the plenary assembly.  There had been 3 meetings between MONEYVAL advisors and the Holy See – two on site visits of MONEYVAL advisors to the Vatican and a meeting in Strasbourg. All the work of the Holy See’s« financial branch » are in preparation for the 4^th of July meeting.

The efforts of the Holy See for financial transparency

The fact that the Holy See changed law n.127 just one year after its promulgation in order to make it adhere to international standards shows the Holy See’s specific and long term commitment to transparency. Yet, the reform had been particularly resisted by the «architects »  of the «old » law n. 127. Among these architects, Card. Attilio Nicora, president of the Authority of Financial Information, defined the new law as «a step back » . Ettore Gotti Tedeschi was also among the critics. He did not formally take part in the drafting of the old law. But he recommended  Marcello Condemi and Francesco De Pasquale as advisors, who were later appointed member and president, respectively, of the Authority for Financial Information.  They came from the Bank of Italy ranks and .defended wholeheartedly the law.

The old law n. 127 would «justify » Gotti Tedeschi’s decision – questionable, according to several observers – to declare before Italian magistrates about 23 million transferred by the IOR in 2010, although the magistrates did not make a proper international request. Gotti Tedeschi also convinced Paolo Cipriani, general manager of the I.O.R., to go and speak to the Italian magistrates. Cipriani was in favor of Holy See transparency, and at the same time he wanted to protect Holy See sovereignty. With the Guardia di Finanza (the Italian financial police) Cipriani holds informal relationships: anytime he is asked for information, he fulfill the request, except in the cases that would be detrimental to the sovereignty of the Holy See. The Guardia di Finanza once sent him a note to thank him for his quickness and precision in his answers.

A man rebuilding his image

So, there is a whole world in the Holy See that keeps on working, while outside the Vatican City State Ettore Gotti Tedeschi is on the spot. If, in the past, the former president of the I.O.R. was seen a strong defender of transparency, now Ettore Gotti Tedeschi is projecting his image of a person under attack, in order to get back to the previous image. In fact, his behavior has been censored by many inside the Vatican. The memorandum of the meeting of the board of Superitendance of the I.O.R. that voted the no confidence on Gotti Tedeschi listed nine accusations against the president of the I.O.R. Among these, one was of «erratic »  behavior. And Ettore Gotti Tedeschi seems to keep on his erratic behavior even now that he is out of the Vatican.

Vatican transparency

During his two years and a half as president of the board of Superintendence, Ettore Gotti Tedeschi collected a lot of information, and some of it is being leaked to the press. The media polemicizes the ciphered accounts of the I.O.R. But this should not be shocking:  the I.O.R. is not a bank. It is a “Pontifical body”, whose funds are at the disposal of the Pope. It is something more similar to a Trust than to a bank. I.O.R. accounts have always been given ciphered codes, rather than names, even if the accountes are not secret, and the information on them is complete. The «transparency operation »  began under Angelo Caloia, president of the body of Surveillance of the I.O.R. before Gotti Tedeschi. Since 2002, Caloia adopted the KYC policy, i.e. Know Your Customer. Each customer of the Institute was carefully analyzed. Obviously, since it is not a bank, I.O.R. cannot transfer money by itself. So it opens several bank accounts – especially in Deutsche Bank -  and there the money is transferred, and all the money movements can be traced. Since  the promulgation of the Vatican anti-money laundering law, each transfer must be justified and explained in a very precise manner, and that is why I.O.R. asks its customers to fill an appropriate form that some customers do not like. It is not even newswothy that in the I.O.R. there are the so called « lay » accounts, i.e. accounts that do not belong to cardinals or religious congregations, but to people outside of the Holy See. The opening of this kind of accounts is also covered in the anti-money laundering law. Paolo Cipriani – the I.O.R. general manager – said in an interview published on the Italian newspaper Il Corriere della Sera that there are no numbered accounts at the Vatican bank and the only Italians, apart from priests, monks and nuns, who banked with the IOR were lay employees or pensioners of the Holy See. Cipriani added that Gotti Tedeschi had been invited to inspect lists of accounts, but – Cipriani says – «he didn’t take things in hand. It was as if he were absent, even when he was present».

(false) Information

All of these (false) information is part of a strong press campaign. Gotti Tedeschi could not come to terms with receiving a no confidence vote by the board of I.O.R. and a press release that some observers defined « a declaration of war » . Several Italian media outlets proposed an external commission to evaluate how Ettore Gotti Tedeschi worked in the I.O.R. And his friends in finance and industry defended Ettore Gotti Tedeschi on the prominent Italian newspaper Il Corriere della Sera. After that, they tried to set up a sort of independent commission whose spokesperson would be Vito Gamberale, president of the Fund F2i, among whose members is Gotti Tedeschi.. Then, after the raid that brought to the seizure of his papers, and so also of the I.O.R. document, it seems that Gotti Tedeschi thought that he could trumpet his view through the Italian magistrate – the public prosecutor of Rome denied to have taken “Vatican” dossiers, but maybe the public prosecutor of Naples will do it; finally, it also seems that he may want to write a book, a Vatican best-seller that will forever save him from the accusation of being erratic.

More or less fanciful stories of how things went on come out from the same circles that spread misinformation about Gotti Tedeschi being under attack. And so we could read that Gotti Tedeschi had been fired because everybody in the Vatican opposed his transparency policy. Even that Gotti Tedeschi was victim of the American lobby of the Knights of Columbus.  The drafter of the memorandum of no confidence, Carl A. Anderson, was also among the first to speak up against Gotti Tedeschi in the Vatican.  A letter from Anderson criticizing the former president of the I.O.R. has been leaked to the press.  Anderson is the Supreme Knight of the Knights of Columbus. But fact, the Knights of Columbus are beyond suspicion. Their founder, Michael J. McGivney, is going to be beatified. They cooperate with the Holy See since the Benedict XV pontificate, they do not hesitate to send financial aid when requested, and they help poor. The wealth of the Knights of Columbus comes from a leading insurance society they manage, which has always gained Triple A financial ratings for its reliability.

Was there a war?

That the Knights of Columbus would like to take possession of the Holy See, getting rid of Opus Dei, is unsubstantiated. It was not only Carl A. Anderson statements and opinion that brought about the no confidence vote on Gotti Tedeschi. The four members of the board of Surveillance of the I.O.R., completely agree, and as the letters leaked to the Italian newspaper Il Fatto Quotidiano show.  Both Carl A. Anders and Rolando Schmitz – another member of the board – recommended the no confidence on Gotti Tedeschi. The letters were addressed to Cardinal Bertone, the “president” of the Commission of Cardinals that manages the I.O.R. Rolando Schmitz also wrote to Bertone that he would resign if an eventual no confidence vote of the board would not be confirmed by the commission of cardinals.

A press release

All of these rumors – coming out from circles very close to Gotti Tedeschi, and some say from Gotti Tedeschi himself – damage the reputation of the Holy See. This why the Holy See wanted to do away with the utter chatter with the Friday, 8^th of June press release underlining its « surprise and concern»  for the «recent events »  involvingEttoreGotti Tedeschi. The Holy See also says that it trusts that «the prerogatives acknowledged to the Holy See by the international legal order are being adequately considered and respected »  by the Italian judicial authorities.

The Holy See statement is a message to the Italian magistrates that are canvassing and studying the Gotti Tedeschi memorandum of its days as president of the I.O.R. In fact, the Italian public prosecutor denied to have taken documents about the I.O.R.: those papers had been found, seized and then sealed. But the investigators obviously glanced them. And the Holy See reminds all that those are documents from a sovereign country, seized to an ex president of a « body of State ».

Even if Gotti Tedeschi does not enjoy a “functional” immunity as president of the I.O.R. since the no confidence vote, those papers are from the time when he was in charge, and they are not part of the enquiry on Finmeccanica. The Holy See press release goes beyond, setting the record straight about what has been written during these days. First of all, «the Holy See confirms his full trust in the people whoworkat theInstitute for Religious Works with commitment and professionality»; and it is « examining with the maximum care»  the possible damage infringed upon the rights of the Institute and of its bodies. So, there is the possibility of a legal action. And this possibility upholds the « transparency line »  wanted by Benedict XVI: there is nothing to hide, and so there is nothing to deny. There is simply a desire to do away with any falsity.

What the Holy See is doing

The raid of the house and the office of Ettore Gotti Tedeschi gave rise to the rumors about the motives of the no confidence vote. Even in this case, it was the same I.O.R. to speak in a fair and strong manner – even too candidly for some internal observers. The Holy See confirms once again that the « no confidence vote on Ettore Gotti Tedeschi by the Board of Superintendence was rooted on objective reasons, concerning the governance of the Institute, and not determined by a presumed opposition to transparency, which the Holy See and the I.O.R. itself particularly care for».

So much care that it reworked the law n. 127 anti money-laundering not even one year after its promulgation. Holy See is working to fulfill the European request and to adhere to the international standars. For what concern the new law, MONEYVAL advisors focused on the new role of the Authority of Financial Information, that it is still crucial on the anti money-laundering law of the Holy See, but that it is now placed in a larger institutional settings that includes the State Secretariat, the Vatican City State Administration and the Gendarme Corps. The “presence” of the Secretariat of State among the bodies involved in trasparency – it deals with internal and international policy – does not seem to be evaluated negatively by te MONEYVAL advisors.  For what concerns the “controlled” body, the I.O.R. seems to be evaluate for great part adherent to the international standards. This would contrast the accusation of Gotti Tedeschi. Who told that he had been «fired because of his work for transparency». And whose story is taking attention away from the Holy See work.

His reform is something more similar to Gregory VII. That of Gregorian reform is an heroic enterprise, brought on by a few man that works to re-moralized their society and so purify the Church. People gathered around Ildebrando of Soana begins a movement whose effect were so vast that a whole world change. Will this happen with the Benedict XVI’s Papacy?

Elected Pope with the name of Gregory VII, Ildebrando do not only care about the purification and moralization of the Church. He also collect the ancient sources, so creating a corpus of papers that will be the first global law of the world, the Canon Law. More, he defends the autonomy of the Church. In Dictatus Papae, Gregory VII affirms the supremacy of the Pope on any other power, the imperial one included. Then, he organizes the Pontifical Legates network. He establishes two kind of Pontifical Legates: the one in loco, charged by the Pope to look after the application of Gregorian reform on a territory; and the one sent by  Rome to accomplish mission in a foreign countries. The defense of the autonomy and sovereignty of the Church is also brought on, during the Gregorian Age, by creating new canonic collection. Gregory VII auspicates the research of the sources of the law, and so many researchers look for documents that affirms that the Papal authority is the source of the law. This research will bring to light the writings of Attone, Anselm from Lucca, Deusdedit.

It is the work Benedict XVI is doing as well. Joseph Ratzinger began his theological research with his Doctoral thesis on the «People of God and House of God in Saint Augustine’s Doctrine of the Church» – defended in 1951 -, and he has always been aware that he needed to look back to the Church, and then he understood that the Church needed to be less worldy, and that being less wordly means to change and unify. Finally, the Canon Law is the tool that the Church has to do it.

Benedict XVI wants to focus on Canon Law, and this is one of the reasons why the Secretary of State is a Canonist and the last Papal nuncios appointed is Charles J. Brown, a non diplomat that served for years in the Congregation for the Doctrine of the Faith. This comeback of the Canon Law is driving the Benedict XVI’s choice for what concern international relations, and even for what concern its commitment for financial transparency. This led to a renewed Vatican anti-money laundering law. Not everybody had been happy about it, inside and outside the Vatican Walls. Why?

The new text of anti-money laundering Vatican Law come into effect

There had been no modification to the Decree n. 159 issued by the Pontifical Commission for Vatican City State. The last 25th of January, Holy See issued the decree n. 159 to amend the Vatican City State Law n. 127 concerning the countering of money laundering and financing of terrorism. As the art. 7 of the Fundamental Law of Vatican City State, the President of the Pontifical Commission for Vatican City State  «in cases of urgent necessity, he can issue dispositions having the force of law, which  however lose their force if they are not confirmed by the Commission within ninety days». The Commission confirmed the decree and – beyond whatever it has been written and told during these last three months – there were no doubts about it.

Anti money-laundering Vatican law: a never ending debate

Ever since the Law n. 127 had been issued, the Governatorate knew that this law had been written in a hurry, under the pressure of the investigation of the Public Prosecutor of Rome on two money transfer ordered by the I.O.R. (the Institute for Religious Works), and with the necessity to fully comply to the norms required by the European Union in the Monetary Convention signed by the Holy See in 2009. Yet while Holy See and European Union were discussing the terms of the Monetary Convention, the then number two of Vatican City State Carlo Maria Viganò showed himself doubtful about what the on-going discussion was going to ask to the Holy See, and proposed to unhook the Holy See by Euro area, in order to preserve its sovereignty.

The law n. 127 reassured Italian prosecutors, but on the other hand it did not completely fit to the international standards. The decree was an improvement of the law promoted by the Vatican City State administration in order to fit to international standards and at the same time to let them adhere to a peculiar State that is Vatican City State, while preserving the Holy See sovereignty.

An Italian problem?

Yet, during these last three months, Italian medias highlighted several rumors coming from «inside the Vatican» against the improvement of the law 127. Il Fatto Quotidiano – one of the most prominent and aggressive Italian newspaper – published a series of leaks of reserved documents. Among these documents, there was also an e-mail sent by the Director of the Authority for Financial Information Francesco De Pasquale (the controller) to the president of the Council of Superintendency of the I.O.R. (the controlled). This documents proved a questionable relationship between two parts of the mechanism of control of the Holy See, and at the same time proved that an animated debate took place within the Sacred Walls about the improvement of the Vatican Law n. 127.

It had been also leaked to Il Fatto Quotidiano a notation by cardinal Attilio Nicora, president of the Authority for Financial Information (but also member of the Council of Superintendecy of the I.O.R., member of the Commission for the Governatorate of Vatican City State and member of the so-called Council of 15, the assembly of 15 cardinals that periodically meet to take stock of the Vatican financial situation). In this notation, Nicora described the amendments to the Law n. 127 as “step behind” confronting with the previous text, which he blessed and promoted. More. The last March, the 19th, an article published on Il Corriere della Sera, the most spread Italian newspaper, let understand that Nicora himself was working to rewrite the text of the decree n.159, in order to bring the law back to the “old” law n. 127. The article proved that – inside the Vatican – the debate never ended.

Why the anti-money laundering law changed

The amendments to the Law n.127 had been requested by the advisors of MONEYVAL, the body of the Council of Europe that analyze and judge the adherence of the States to the 40+9 GAFI recommendations for contrasting money laundering and financing of terrorism. Marcello Condemi, a member of the Vatican Authority for Financial Information and draftsman of the first sketch of the old law n. 127, worked on a second sketch of the law right after the first on site visit of the MONEYVAL advisors in Vatican, that took place in November 2011. Several debates within the Sacred Walls followed. Finally, with the decree n. 159, the law n. 127 had been essentially modified. The “new” law n. 127 is now more adherent to international standard. It strengthens the power of controlling of the Authority for Financial Information, but at the same time distributed the controlling powers on several bodies of the Holy See, according to the principle of the separation of powers (even the Gendarm Corps is now encouraged to strengthen its intelligence in order to take part to the countering of money laundering with proper tools of investigation).  It gave to the Vatican Secreteriat of State the complete management of the relationships between States – «The Secretariat of State – it is written in the decree n. 159, art. 2 quinquies – foster the adhesion of the Holy See to treaties and international agreements, as well as the relations and the participation of the Holy See to institution and international organization qualified to define norms and good practices for what concerns the prevention and countering of money laundering and financing of terrorism».

That the effort of the Holy See had been to adhere to international standards for what concerns the countering of money laundering without denaturalize its own institution is evident when – in the decree n. 159 – the procedures to take into consideration the list of terror organizations issued by the Security Council of United Nations. According to the law n. 127, Holy See does not mechanically transpose the United Nations Lists. This choice is aimed to preserve the Holy See and Vatican neutrality. In fact, lists are written under the «Chapter 7» of Charter of the United Nations, and that Chapter is applied in war time. Holy See could be embarrassed by a mechanical transposition of the lists, since it could be in contradiction with the Holy See orientation –  Holy See is traditionally neutral and in favor of peace. Since Holy See is a Permanent Observer to the Assembly of United Nations, and not a Full Member, a settlement has been made to the autonomy of the Holy See: the Vatican Secretariat of State – according to the new article 24 of the law n. 127– will draw up its own list of terror organizations that will be based on the one issued by the United Nations, so keeping its autonomy, and at the same time showing to be sensitive to the international security goals. Holy See so maintain its autonomy, but at the same time proves sensibility to the international security goal .

Is there a biggest target?

Maybe there is a biggest target on the basis of the polemics that followed the one the another from the moment in which the Holy See began the process enrolled in the «White List», the list of states most active in preventing and fighting the financial crimes.. The critics to the lack of transparency of Vatican finance would hide a sort of attack to the sovereignty of the Holy See itself. Documents leaked by the press – the so-called Vatileaks, that are now under the investigation of a commission made up of the cardinals Herranz, De Giorgi and Tomko – prove that the «sovereignty issue» has never been taken into consideration by the «step behind» theorists. The leaks are about the retroactivity of the «new» law n. 127; about the will to cooperate with Italian investigators; about a diligence toward Italian authorities that led Ettore Gotti Tedeschi to be voluntarily questioned by the Italian magistrates without these latter submitted the request internationally.

Yet, Paolo Cipriani, General Director of the Institute for Religious Works, explained – during one of the seminars periodically held by the I.O:R. to train the administrators of the Congregation with deposits in the «Vatican bank» – that the Institute has always responded to any request submitted by Prosecutors or Central Banks. The responses by the Holy See, Cipriani explained, had come formally – there had been during the last ten years 20 requests submitted internationally to the Holy See (it is a global data, it does not concerns the only I.O.R.): 19 had been fulfilled by the Vatican City State, the last one has been judged by a Vatican Court – and not formally, for a sort of «good neighborhood relationships» with the other financial institutes. Holy See – Cipriani also underlined – did not answer in the only case the request would be considered a vulnus to its sovereignty.

A wider – international – perspective

It is now time to see things from a wider perspective. The announcement of the improvement of the law n. 127 has been launch in the Osservatore Romano, the newspaper of the Holy See, in an article by msgr. Dominique Mamberti, the «foreign minister» of the Holy See. Mamberti linked the news of the improvement of the law n. 127 to the ratification by the Holy See of three international threaties – the news about the ratification had been given the 25th of January as well. Holy See adhered to and ratified the International Convention for the Suppression of the financing of terrorism(Onu, New York, 1999) and the United Nations Conventions against the transnational organized crime (Palermo, 2000). Holy See also announced the ratification of the United Nations Convention against illicit traffic in narcotics drugs and psychotropic substances (Wien, 1998): this latter Convention had been already signed by the Holy See when it had been adopted by United Nations.

It’s a long time that the campaigns to expell Holy See by the concert of Nations – as the See Change campaign – broke down in the public opinion. In 2007, The Economist – one of the most authoritative magazines in the world – published an article headlined “God’s ambassadors” about the Vatican diplomacy. The article ended with this advice for the Holy See: «It could renounce its special diplomatic status and call itself what it is – the biggest non-governmental organization in the world».

Within the bureaus of the United Nations and of the other major international organization in which the Holy See seats as an observer, the idea to expel Holy See from the concert of nations is widely spreads. Even if this idea did not succed, and – on the other hand – on July 2004 the General Assembly of United Nations approved a resolution that not only confirm, but even enhanced the presence of the Holy See within the United Nations.

So, a more subtle strategy began. This strategy – brought on in international environments – aims to undermine the moral power of the Catholic Church and of religions in general. It consists in remarking that religious freedom is something like the freedom of expression, or in confusing the religious freedom with the freedom of worship. Vatican diplomacy is undermined, too. If Italian Prime Minister Mario Monti caused an «earthquake» at the Italian Ministry for Foreign Affair by showing his intention to appoint ambassadors not raised up with a diplomatic career, Vatican insiders refer about the intention to appoint lay people as diplomatic representative of the Holy See. Pontifical Legates must be bishops, since they represent the Pope. This rule is valid and effective only for Papal nuncios: they work as Papal ambassadors, they keep relationships with the governments, and at the same time they work as bishops, speaking to the Episcopal Conferences of the countries they are appointed at, give their opinion about the to-be-appointed bishops.

Nuncios that are appointed as permanent observer within the International organizations (United Nations, U.N.E.S.C.O., F.A.O., European Parliament) must only care the relationships between the Holy See and the governments. This would open to the appointment of lay people as permanent observers of the Holy See.

Could this be the beginning of a weakening of the Vatican diplomacy? In the book C’era una volta un Vaticano (Once upon a time a Vatican), Massimo Franco, underlines this lack of international appeal of the Holy See. Too appeased on Italy and on its relations with Italy – Massimo Franco writes .- the Holy See lost sight of its wide global horizon that made of it the most long-lived and solid institution in the world. Canon right is the first really global and globalized law of the history, and it still consists in a solidity that no friendly diplomatic relations would touch.

This same problem spoiled the path to the Vatican financial transparency. Holy See borders are not anymore with Italy, but with the whole Europe. Yet, the members of the Authority for Financial Information are all Italian, coming from the Bank of Italy milieau – even if the Bank of Italy proved a certain hostility toward the Holy See (the investigation of the Roman prosecutors undermined the Holy See sovereignty, since prosecutors asked for information to the Financial Intelligence Unit of the Bank of Italy – which should be independent – instead of investigating with the Guardia di Finanza).

The “old” law n. 127 would have probably solved the “judicial” problems with Italy, but certainly it would also set back – if not avoided – the Holy See path to the white list. The Plenary Assembly of MONEYVAL will meet the next July, and on that occasion the report about Holy See will be issued. It will not be at that moment that the Council of Europe will decide about the enlistment – or the not enlistment – of the Holy See among the virtuous States. But probably, the possibility to be part of the white list would have been more difficult without the improvement of the law n. 127, that the MONEYVAL advisors auspicated.