FinCEN advisory on jurisdictions with AML and CFT deficiencies

The Financial Action Task Force (FATF) recently updated its list of jurisdictions that have strategic deficiencies in their anti-money laundering (AML) and counter-terrorist financing (CFT) regimes.

As a result of this, the US Financial Crimes Enforcement Network (FinCEN) has issued an advisory (FIN-2016-A001) to provide financial institutions with guidance on reviewing their obligations and risk-based approaches with respect to certain jurisdictions.

Suspicious Activity Report

The FATF has updated two documents identifying jurisdictions that are either subject to its call to apply countermeasures or enhanced due diligence due to their AML/CFT deficiencies and jurisdictions with AML/CFT deficiencies.

FinCEN’s recently issued advisory summarises the changes made to the respective lists.

It also reiterates that a financial institution must file a Suspicious Activity Report if it “knows, suspects, or has reason to suspect that a transaction involves funds derived from illegal activity or that a customer has otherwise engaged in activities indicative of money laundering, terrorist financing, or other violation of [US] federal law or regulation.”

Deficient countries

The FATF has identified Afghanistan, Algeria, Angola, Bosnia and Herzegovina, Guyana, Iraq, Lao PDR, Panama, Papua New Guinea, Syria, Uganda and Yemen as jurisdictions having deficiencies in their AML/CFT regimes, for which they have developed an action plan.

Moreover, FATF has called on Iran and North Korea to apply countermeasures and on Myanmar to apply enhanced due diligence.

Improved countries

Ecuador and Sudan have been removed from the FATF listing and monitoring process due to their significant progress in establishing the legal and regulatory framework to address all or nearly all their strategic AML/CFT deficiencies on a technical level.

These jurisdictions will work with their respective FATF-Style Regional Bodies as they continue to address the full range of AML/CFT issues identified as part of the mutual evaluation process.

FIN-2016-A001 can be found here



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