On November 12, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) released an advisory of the Financial Action Task Force (FATF), which identified jurisdictions with anti-money laundering (AML) and combatting the financing of terrorism (CFT) deficiencies.  FATF, an inter-governmental policy-making body that develops and promotes policies to combat money laundering and terrorist financing, published its most recent list of “high-risk and non-cooperative jurisdictions,”  which was identified as AML/CFT deficient at the end of October.  FATF’s list identifies jurisdictions that have “strategic deficiencies” and works with them to address those deficiencies that threaten global financial markets.

Notably, Argentina, Cuba, Ethiopia, Tajikistan, and Turkey have been removed from the FATF listing and monitoring process given their “significant” progress in addressing all or nearly all of their AML/CFT deficiencies.  Guyana, on the other hand, has been added to the list.

Financial institutions should be mindful of the following and may need to exercise heightened due diligence or caution when conducting transactions with certain jurisdictions, or forego doing business with certain of these countries altogether:

  • Both Iran and North Korea continue to remain subject to FATF’s call on its members and other jurisdictions to apply countermeasures to protect the international financial system from the on-going and substantial money laundering and terrorist financing risks emanating from these jurisdictions.
  • Algeria, Ecuador, Indonesia, and Myanmar have been designated as jurisdictions subject to enhanced due diligence, given their failure to make sufficient progress in addressing AML/CFT deficiencies.
  • FATF identified the following jurisdictions as having deficiencies in their AML/CFT regimes, for which they have developed a plan of action with FATF: Afghanistan, Albania, Angola, Argentina, Cambodia, Guyana,  Iraq, Kuwait, Lao PDR, Namibia, Nicaragua, Pakistan, Panama, Papua New Guinea, Sudan, Syria, Uganda, Yemen, and Zimbabwe.