United States Financial Action Task Force
(FATF)
List of Jurisdictions with Strategic Deficiencies in
Anti-Money Laundering
Introduction:
In 2020, the United States’ Financial Crimes Enforcement Network (FinCEN) issued their advisory to financial institutions of updates to FATF’s list of jurisdictions with strategic anti-money laundering and counter-proliferation financing deficiencies. FATF continues to monitor compliance with its international standards and identify jurisdictions having strategic deficiencies in their own regimes.
Background:
The FATF is a 39-member intergovernmental body, including the U.S., that establishes international standards to combat money laundering and counter the financing of terrorism and proliferation of weapons of mass destruction.
Jurisdictions identified by the FATF as High-Risk Jurisdictions. The FATF’s “High-Risk Jurisdictions Subject to a Call for Action” statement remains in effect on both:
- DPRK and
- Iran.
FATF publicly identifies jurisdictions that are actively working with it to address strategic deficiencies and has made initial determination that:
- Iceland and
- Mongolia
have substantially completed their action plans, and issued statements noting their progress. However, Iceland and Mongolia will remain identified as “Jurisdictions under Increased Monitoring” until the FATF can conduct on-site visits to verify that each country has begun implementing its reforms..
Jurisdictions under Increased Monitoring for 2020 and remaining in effect as of the date of this article are:
- Albania,
- The Bahamas,
- Barbados,
- Botswana,
- Burma (Myanmar),
- Cambodia,
- Ghana,
- Iceland,
- Jamaica,
- Mauritius,
- Mongolia,
- Nicaragua,
- Pakistan,
- Panama,
- Syria,
- Uganda,
- Yemen, and
- Zimbabwe.
Suspicious Activity Reports (SARs):
If a financial institution 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 federal law or regulation, the financial institution must file a SAR. When filing a SAR, financial institutions should provide all pertinent available information in the SAR form and narrative to indicate a connection between the suspicious activity being reported and the activities which have been crucial to identifying proliferation financing, other financial crimes associated with foreign and domestic political corruption, money laundering, and terrorist financing.
Summary:
International banking relationships are complicated and going through a series of new legislative Bills that make compliance confusing while placing a person or the person’s business in jeopardy of civil and/or criminal examinations and the related serious financial and possible incarceration penalties. Our firm can assist your business with compliance matters, an upcoming examination, or audit proceedings at the civil or criminal level.
