Regulatory Alerts2012-07-06 | Circular 3/2012 (GW)BaFin Circular 3/2012 on FATF Updates for Iran, North Korea and High-Risk Jurisdictions
BaFin issued Circular 3/2012 to implement the FATF's June 2012 public statement, placing Iran and North Korea in a category subject to direct counter-measures while adding sixteen nations to a strategic deficiency tier that mandates enhanced due diligence and organizational safeguards. Financial institutions must apply these heightened risk-based measures to cross-border business relationships and transactions, ensuring all security reviews are thoroughly documented for internal audit and financial statement verification. The circular further clarifies that the statutory obligation to file suspicious transaction reports under Section 11 of the German Money Laundering Act persists even when customers withdraw unexplained transaction requests, provided factual indicators of illicit asset origins or terrorist financing remain present.