advisory Based On Fatf Identified Jurisdictions On Increased Monitoring October 2022

NIGERIAN FINANCIAL INTELLIGEN NFIU INTEGRITY & DILIGENCE NIGERIAN FINANCIAL INTELLIGENCE UNIT

ADVISORY NFIU/EXT/PUB/ADV/AC-STEI/OCT-2022/VOL.I/008

UPDATE OF THE FINANCIAL ACTION TASK FORCE (FATF) IDENTIFIED JURISDICTIONS UNDER INCREASED MONITORING IN OCTOBER 2022

The Nigerian Financial Intelligence Unit (NFIU) In fulfilment of its obligations on the timely provision of guidance to Reporting Entities and Competent Authorities (CA) publishes Indicators and advisory on crimes of money laundering and terrorist financing in an effort to guide Reporting Entities and Competent Authorities on observable trends and patterns to mitigate AML/CFT/CPF threats. OCTOBER 2022

NFIU INTRODUCTION In October 2022, the Financial Action Task Force (FATF) updated its list of jurisdictions under In October 2022, the Financial Action Task Force (FATF) updated its list of jurisdictions under increased monitoring and working closely with these countries to address strategic deficiencies in increased monitoring and working closely with these countries to address strategic deficiencies in their regimes to counter Money Laundering, Terrorist Financing and Proliferation Financing1. Their regimes to counter Money Laundering, Terrorist Financing and Proliferation Financing1. The FATF and FATF- Style regional bodies (FSRBs) continue to work with the jurisdiction below as FATF and FATF- Style regional bodies (FSRBs) continue to work with the jurisdiction below as they report on the progress achieved in addressing their strategic deficiencies. They report on the progress achieved in addressing their strategic deficiencies. The FATF calls The FATF calls these jurisdictions to complete their action plans expeditiously and within the agreed timeframe. these jurisdictions to complete their action plans expeditiously and within the agreed timeframe. This list is often referred to as the “grey list”. This list is often referred to as the “grey list”. The FAFT welcomes commitment and will closely The FAFT welcomes commitment and will closely monitor their progress and encourages its members and all jurisdictions to take into account the monitor their progress and encourages its members and all jurisdictions to take into account the information presented below in their risk analysis. Information presented below in their risk analysis. The changes might affect Nigerian Financial The changes might affect Nigerian Financial and Designated Non-Financial Institutions' obligations and Risk-Based Approaches (RBA) with and Designated Non-Financial Institutions' obligations and Risk-Based Approaches (RBA) with respect to relevant jurisdictions. respect to relevant jurisdictions.

The Nigerian Financial Intelligence Unit (NFIU) is issuing this advisory to update all Financial The Nigerian Financial Intelligence Unit (NFIU) is issuing this advisory to update all Financial Institutions (FIs), Designated Non-Financial Institutions (DNFIs), Regulatory/Supervisory Institutions (FIs), Designated Non-Financial Institutions (DNFIs), Regulatory/Supervisory Authorities, Law Enforcement/Anti-Corruption Agencies, Security & Intelligence Agencies, the Authorities, Law Enforcement/Anti-Corruption Agencies, Security & Intelligence Agencies, the Judiciary and all relevant stakeholders in the Anti-Money Laundering and Countering the Judiciary and all relevant stakeholders in the Anti-Money Laundering and Countering the Financing of Terrorism and Counter-Proliferation Financing (AML/CFT/CPF) regime in Nigeria Financing of Terrorism and Counter-Proliferation Financing (AML/CFT/CPF) regime in Nigeria regarding new updates to the FATF list of jurisdictions with strategic AML/CFT/CPF deficiencies, regarding new updates to the FATF list of jurisdictions with strategic AML/CFT/CPF deficiencies, to be on alert when establishing any form of business transaction with entities or individuals and to be on alert when establishing any form of business transaction with entities or individuals and or conducting financial transactions, including inward or outward transfers, with the following or conducting financial transactions, including inward or outward transfers, with the following jurisdictions that have been identified to have strategic deficiencies in their AML/CFT/CPF regime jurisdictions that have been identified to have strategic deficiencies in their AML/CFT/CPF regime and pose a risk to the international financial system. and pose a risk to the international financial system. FIs and DNFIs should consider the FATF's FIs and DNFIs should consider the FATF's statements when reviewing their obligations and risk-based policies, procedures, and practices statements when reviewing their obligations and risk-based policies, procedures, and practices with respect to the jurisdictions noted below. with respect to the jurisdictions noted below.

The FATF in October 2022 identified and updated the list of “Jurisdictions under Monitoring and The FATF in October 2022 identified and updated the list of “Jurisdictions under Monitoring and jurisdiction which are no longer subjected to Increased Monitoring” as demonstrated below; jurisdiction which are no longer subjected to Increased Monitoring” as demonstrated below;

1The Financial Action Task Force (FATF) list of jurisdictions under increased monitoring can be found in full on its website and can be accessed at 1The Financial Action Task Force (FATF) list of jurisdictions under increased monitoring can be found in full on its website and can be accessed at (FATF-PLEN(2022)56.en.pdf_REPORT BY THE ICRG CO-CHAIRS.pdf) Accessed 21.10.2022 (FATF-PLEN(2022)56.en.pdf_REPORT BY THE ICRG CO-CHAIRS.pdf) Accessed 21.10.2022

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NFIU • Since the start of the COVID-19 pandemic, the FATF has provided some flexibility to • Since the start of the COVID-19 pandemic, the FATF has provided some flexibility to jurisdictions not facing immediate deadlines to report progress on a voluntary basis. jurisdictions not facing immediate deadlines to report progress on a voluntary basis. The The following listed countries had their progress reviewed by the FATF since June 2022: following listed countries had their progress reviewed by the FATF since June 2022: Albania, Barbados, Burkina Faso, Cambodia, Cayman Islands, Haiti, Jamaica, Jordan, Albania, Barbados, Burkina Faso, Cambodia, Cayman Islands, Haiti, Jamaica, Jordan, Mali, Morocco, Myanmar, Nicaragua, Pakistan, Panama, Philippines, Senegal, South Mali, Morocco, Myanmar, Nicaragua, Pakistan, Panama, Philippines, Senegal, South Sudan, Turkey, and Uganda. Sudan, Turkey, and Uganda. For these countries, updated statements are provided below. For these countries, updated statements are provided below. • Gibraltar chose to defer reporting; As such, the statement issued in June 2022 for that • Gibraltar chose to defer reporting; As such, the statement issued in June 2022 for that jurisdiction is included below, but it may not necessarily reflect the most recent status of jurisdiction is included below, but it may not necessarily reflect the most recent status of the jurisdiction's AML/CFT regime. The FATF urges Myanmar to work to fully address its the jurisdiction's AML/CFT regime. The FATF urges Myanmar to work to fully address its AML/CFT deficiencies and Myanmar will remain on the list of countries subject to a call for AML/CFT deficiencies and Myanmar will remain on the list of countries subject to a call for action until its full action plan is completed. action until its full action plan is completed. • Following review, the FATF now also identifies the Democratic Republic of the Congo, • Following review, the FATF now also identifies the Democratic Republic of the Congo, Mozambique, and Tanzania. Mozambique, and Tanzania. • Nicaragua and Pakistan jurisdiction are no longer subjected to increase monitoring by • Nicaragua and Pakistan jurisdiction are no longer subjected to increase monitoring by FATF. FATF.

The full update to the list follows and is also available via the FATF website2. The full update to the list follows and is also available via the FATF website2. In addition to the “Jurisdictions under Monitoring”, the FATF also maintain a list of “High Risk In addition to the “Jurisdictions under Monitoring”, the FATF also maintain a list of “High Risk Jurisdictions Subject to a Call for Action". Jurisdictions Subject to a Call for Action". However, on 2 August 2020, FATF decided to pause the However, on 2 August 2020, FATF decided to pause the review process for the list of High-Risk Jurisdictions subject to a Call for Action. review process for the list of High-Risk Jurisdictions subject to a Call for Action. Therefore, please Therefore, please refer to the statement on these jurisdictions adopted in February 2020. refer to the statement on these jurisdictions adopted in February 2020. While the statement may While the statement may not necessarily reflect the most recent status of Iran and the Democratic People's Republic of not necessarily reflect the most recent status of Iran and the Democratic People's Republic of Korea's AML/CFT regimes, the FATF's call for action on these high-risk jurisdictions remains in Korea's AML/CFT regimes, the FATF's call for action on these high-risk jurisdictions remains in effect3. effect3.

Jurisdiction subject to a FATF call on its members and other jurisdictions to apply enhanced due Jurisdiction subject to a FATF call on its members and other jurisdictions to apply enhanced due diligence measures proportionate to the risks arising from the jurisdiction. diligence measures proportionate to the risks arising from the jurisdiction.

2FATF-PLEN(2022)56.en.pdf_REPORT BY THE ICRG CO-CHAIRS.pdf 2FATF-PLEN(2022)56.en.pdf_REPORT BY THE ICRG CO-CHAIRS.pdf 3ibid 3ibid ADVISORY Page 3 |19

NFIU TABULAR REPRESENTATION OF JURISDICTIONS IN AND OUT OF THE INCREASED MONITORING LIST THUS FAR IN 2021 OCTOBER OCTOBER 2022

S/ Jurisdictio Jurisdiction Jurisdictio Jurisdiction Jurisdictio Jurisdiction Jurisdiction Jurisdiction N n with s no longer n with s no longer n with s no longer with longer Strategic subject to Strategic subject to Strategic subject to Strategic subject to Deficiencie increased Deficiencie increased Deficiencie increased Deficiencies increased s (October monitoring s (March monitoring s (June monitoring (October monitoring 2021) (October 2022) (March 2022) 2022) (June 2022) 2022) (October 2021) 2022)

1 Albania Botswana Albania Zimbabwe Albania Malta Albania Nicaragua 2 Barbados Mauritius Barbados Barbados Barbados Pakistan 3 Burkina Burkina Burkina Faso Faso Faso 4 Cambodia Cambodia Cambodia 5 Cayman Cayman Cayman Islands Islands Islands The Cayman Island 6 Haiti Haiti Gibraltar Gibraltar The Democratic Republic of Congo 7 Jamaica Jamaica Haiti 8 Jordan Jordan Jamaica Haiti 9 Mali Mali Jordan Jamaica 10 Malta Malta Mali Jordan 11 Morocco Morocco Morocco Mali 12 Myanmar Myanmar Myanmar Morocco 13 Nicaragua Nicaragua Nicaragua Mozambiqu e 14 Pakistan Pakistan Pakistan Myanmar 15 Panama Panama Panama Panama 16 Philippines Philippines Philippines Philippines 17 Senegal Senegal Senegal Senegal 18 South South South South Sudan Sudan Sudan Sudan 19 Syria Syria Syria Syria 20 Turkiye Turkiye Turkiye Tanzania 21 Uganda Uganda Uganda Turkiye 22 Yemen United United Uganda Arab Arab Emirates Emirates 23 Zimbabwe Yemen Yemen United Arab 24 Emirates Yemen

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NFIU JURISDICTIONS WITH STRATEGIC DEFICIENCIES IDENTIFIED BY THE FATF FOR APPLICATION OF ENHANCED DUE DILLIGENCE (OCTOBER 2022) Myanmar In February 2020, Myanmar committed to address its strategic deficiencies. In February 2020, Myanmar committed to address its strategic deficiencies. Myanmar's action Myanmar's action plan expired in September 2021. plan expired in September 2021. In June 2022, the FATF strongly urged Myanmar to swiftly In June 2022, the FATF strongly urged Myanmar to swiftly complete its action plan by October 2022 or the FATF would call on its members and urge all complete its action plan by October 2022 or the FATF would call on its members and urge all jurisdictions to apply enhanced due diligence to business relations and transactions with jurisdictions to apply enhanced due diligence to business relations and transactions with Myanmar. Myanmar. Given the continued lack of progress and the majority of its action items still not Given the continued lack of progress and the majority of its action items still not addressed after a year beyond the action plan deadline, the FATF decided that further action was addressed after a year beyond the action plan deadline, the FATF decided that further action was necessary in line with its procedures and FATF calls on its members and other jurisdictions to necessary in line with its procedures and FATF calls on its members and other jurisdictions to apply enhanced due diligence measures proportionate to the risk arising from Myanmar. apply enhanced due diligence measures proportionate to the risk arising from Myanmar. When When applying enhanced due diligence measures, countries should ensure that flows of funds for applying enhanced due diligence measures, countries should ensure that flows of funds for humanitarian assistance, legitimate NPO activity and remittances are not disrupted. humanitarian assistance, legitimate NPO activity and remittances are not disrupted. Myanmar Myanmar should continue to work on implementing its action plan to address these deficiencies, including should continue to work on implementing its action plan to address these deficiencies, including by: (1) demonstrating an improved understanding of ML risks in key areas; (2) demonstrating that by: (1) demonstrating an improved understanding of ML risks in key areas; (2) demonstrating that on-site/offsite inspections are risk-based, and hundi operators are registered and supervised; (3) on-site/offsite inspections are risk-based, and hundi operators are registered and supervised; (3) demonstrating enhanced use of financial intelligence in LEA investigations, and increasing demonstrating enhanced use of financial intelligence in LEA investigations, and increasing operational analysis and disseminations by the FIU;(4) ensuring that ML is operational analysis and disseminations by the FIU;(4) ensuring that ML is investigated/prosecuted in line with risks; (5) demonstrating investigation of transnational ML investigated/prosecuted in line with risks; (5) demonstrating investigation of transnational ML cases with international cooperation; (6) demonstrating an increase in the freezing/seizing and cases with international cooperation; (6) demonstrating an increase in the freezing/seizing and confiscation of criminal proceeds, instrumentalities, and/or property of equivalent value; (7) confiscation of criminal proceeds, instrumentalities, and/or property of equivalent value; (7) managing seized assets to preserve the value of seized goods until confiscation; and (8) managing seized assets to preserve the value of seized goods until confiscation; and (8) demonstrating implementation of targeted financial sanctions related to PF. demonstrating implementation of targeted financial sanctions related to PF. The FATF urges The FATF urges Myanmar to work to fully address its AML/CFT deficiencies and Myanmar will remain on the list Myanmar to work to fully address its AML/CFT deficiencies and Myanmar will remain on the list of countries subject to a call for action until its full action plan is completed. of countries subject to a call for action until its full action plan is completed.

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NFIU JURISDICTIONS WITH STRATEGIC DEFICIENCIES IDENTIFIED BY THE FATF FOR INCREASED MONITORING (OCTOBER 2022) Albania Since February 2020, when Albania made a high-level political commitment to work with the Since February 2020, when Albania made a high-level political commitment to work with the FATF and MONEYVAL to strengthen the effectiveness of its AML/CFT regime, Albania has taken FATF and MONEYVAL to strengthen the effectiveness of its AML/CFT regime, Albania has taken steps towards improving its AML/CFT regime, including by enacting an adequate legal framework steps towards improving its AML/CFT regime, including by enacting an adequate legal framework for violations of company and NPO registration obligations and Implementing proportionate and for violations of company and NPO registration obligations and Implementing proportionate and dissuasive sanctions against entities that failed to declare their beneficial owners in the registry dissuasive sanctions against entities that failed to declare their beneficial owners in the registry by the deadline. by the deadline. Albania should continue to work on implementing its action plan to address its Albania should continue to work on implementing its action plan to address its strategic deficiencies, including by increasing the number of money laundering indictments that strategic deficiencies, including by increasing the number of money laundering indictments that it brings to court for prosecution. it brings to court for prosecution. The FATF expresses concern that Albania failed to complete its The FATF expresses concern that Albania failed to complete its action plan, which fully expired in February 2022. action plan, which fully expired in February 2022. The FATF strongly urges Albania to swiftly The FATF strongly urges Albania to swiftly demonstrate significant progress in completing its action plan by February 2023 or the FATF will demonstrate significant progress in completing its action plan by February 2023 or the FATF will consider next steps if there is insufficient progress. consider next steps if there is insufficient progress. Additionally, the FATF expresses concern that Additionally, the FATF expresses concern that Albania's plans for a possible Voluntary Tax Compliance (VTC) programme do not comply with Albania's plans for a possible Voluntary Tax Compliance (VTC) programme do not comply with the FATF's principles for managing the AML/CFT implications of VTCs or FATF's best practices the FATF's principles for managing the AML/CFT implications of VTCs or FATF's best practices for such programmes. for such programmes. Albania should revise its draft VTC law and work with MONEYVAL to Albania should revise its draft VTC law and work with MONEYVAL to ensure that any VTC law passed or implemented has adequate safeguards to prevent the potential ensure that any VTC law passed or implemented has adequate safeguards to prevent the potential for abuse of the programme for money laundering or terrorist financing purposes. for abuse of the programme for money laundering or terrorist financing purposes. Barbados Since February 2020, when Barbados made a high-level political commitment to work with the Since February 2020, when Barbados made a high-level political commitment to work with the FATF and CFATF to strengthen the effectiveness of its AML/CFT regime, Barbados has taken FATF and CFATF to strengthen the effectiveness of its AML/CFT regime, Barbados has taken steps towards improving its AML/CFT regime, including by, demonstrating the ability to enforce steps towards improving its AML/CFT regime, including by, demonstrating the ability to enforce breaches of BO requirements, strengthening the relationship between the FIU and LEAS, breaches of BO requirements, strengthening the relationship between the FIU and LEAS, improving the ML database, and demonstrating progress in the investigation, seizure and improving the ML database, and demonstrating progress in the investigation, seizure and forfeiture of cash and assets. forfeiture of cash and assets. Barbados should continue to work on implementing its action plan Barbados should continue to work on implementing its action plan to address its strategic deficiencies, including by: to address its strategic deficiencies, including by: (1) taking appropriate measures to prevent legal (1) taking appropriate measures to prevent legal persons and arrangements from being misused for criminal purposes, and ensuring that accurate persons and arrangements from being misused for criminal purposes, and ensuring that accurate and up-to-date basic and beneficial ownership information is available on a timely basis; (2) and up-to-date basic and beneficial ownership information is available on a timely basis; (2) demonstrating that ML investigations and prosecutions are in line with the country's risk profile; demonstrating that ML investigations and prosecutions are in line with the country's risk profile; (3) further pursuing confiscation in ML cases, including by repatriating or sharing confiscated (3) further pursuing confiscation in ML cases, including by repatriating or sharing confiscated assets with other countries. assets with other countries. The FATF urges Barbados to swiftly complete its action plan as all The FATF urges Barbados to swiftly complete its action plan as all Page 6 |19 ADVISORY

NFIU deadlines have now expired and to address the above-mentioned strategic deficiencies by February 2023. Burkina Faso Since February 2021, Burkina Faso made a high-level political commitment to work with the FATF Since February 2021, Burkina Faso made a high-level political commitment to work with the FATF and GIABA to strengthen the effectiveness of its AML/CFT regime, Burkina Faso has taken steps and GIABA to strengthen the effectiveness of its AML/CFT regime, Burkina Faso has taken steps towards improving its AML/CFT regime, including by adopting and implementing follow-up towards improving its AML/CFT regime, including by adopting and implementing follow-up mechanisms for monitoring actions in the national strategy. mechanisms for monitoring actions in the national strategy. Burkina Faso will work to implement Burkina Faso will work to implement its action plan, including by: its action plan, including by: (1) updating its understanding of ML/TF risks, including through the (1) updating its understanding of ML/TF risks, including through the revision of the national risk assessment in line with the sectoral priorities identified in its national revision of the national risk assessment in line with the sectoral priorities identified in its national strategy; (2) seeking mutual legal assistance (MLA) and other forms of international cooperation strategy; (2) seeking mutual legal assistance (MLA) and other forms of international cooperation in line with its risk profile; in line with its risk profile; (3) strengthening of resource capacities of all AML/CFT supervisory (3) strengthening of resource capacities of all AML/CFT supervisory authorities and implementing risk based supervision of FIs and DNFBPs; authorities and implementing risk based supervision of FIs and DNFBPs; (4) maintaining (4) maintaining comprehensive and updated basic and beneficial ownership information and strengthening the comprehensive and updated basic and beneficial ownership information and strengthening the system of sanctions for violations of transparency obligations; system of sanctions for violations of transparency obligations; (5) increasing the diversity of STR (5) increasing the diversity of STR reporting; (6) enhancing the FIU's human resources through additional, hiring, training and reporting; (6) enhancing the FIU's human resources through additional, hiring, training and budget; (7) conduct training for LEAs, prosecutors and other relevant authorities; (8) budget; (7) conduct training for LEAs, prosecutors and other relevant authorities; (8) demonstrating that authorities are pursuing confiscation as a policy objective; demonstrating that authorities are pursuing confiscation as a policy objective; (9) enhancing (9) enhancing capacity and support for LEAs and prosecutorial authorities involved in combatting TF, capacity and support for LEAs and prosecutorial authorities involved in combatting TF, in line in line with the TF National Strategy; and (10) implementing an effective targeted financial sanctions with the TF National Strategy; and (10) implementing an effective targeted financial sanctions regime related to terrorist financing and proliferation financing as well as risk-based monitoring regime related to terrorist financing and proliferation financing as well as risk-based monitoring and supervision of NPOs. and supervision of NPOs. Cambodia Since February 2019, Cambodia made a high-level political commitment to work with the FATF Since February 2019, Cambodia made a high-level political commitment to work with the FATF and APG to strengthen the effectiveness of its AML/CFT regime. and APG to strengthen the effectiveness of its AML/CFT regime. At its October 2022 Plenary, the At its October 2022 Plenary, the FATF made the initial determination that Cambodia has substantially completed its action plan FATF made the initial determination that Cambodia has substantially completed its action plan and warrants an on-site visit to verify that the implementation of Cambodia's AML/CFT reforms and warrants an on-site visit to verify that the implementation of Cambodia's AML/CFT reforms has begun and is being sustained, and that the necessary political commitment remains in place has begun and is being sustained, and that the necessary political commitment remains in place to sustain implementation and improvement in the future. to sustain implementation and improvement in the future. Cambodia has made a number of key Cambodia has made a number of key reforms, including to improve: reforms, including to improve: (1) MLA law and providing training on MLA to prosecutors and (1) MLA law and providing training on MLA to prosecutors and judges; (2) risk-based supervision for FIs and DNFBPs; (3) the legal framework on preventive judges; (2) risk-based supervision for FIs and DNFBPs; (3) the legal framework on preventive measures and conducting outreach to the casino, real-estate and MVTS sectors; measures and conducting outreach to the casino, real-estate and MVTS sectors; (4) the quality and (4) the quality and ADVISORY Page 7 |19

NFIU quantity of FIU disseminations, demonstrating an increase in ML investigations in line with risk; quantity of FIU disseminations, demonstrating an increase in ML investigations in line with risk; (5) its effectiveness in asset confiscation; and (6) establishing a legal framework for implementing (5) its effectiveness in asset confiscation; and (6) establishing a legal framework for implementing UN sanctions related to targeted financial sanctions for PF and providing training to strengthen UN sanctions related to targeted financial sanctions for PF and providing training to strengthen the skills of competent authorities to implement TFS for PF. the skills of competent authorities to implement TFS for PF. The FATF will continue to monitor The FATF will continue to monitor the COVID-19 situation and conduct an on-site visit at the earliest possible date. the COVID-19 situation and conduct an on-site visit at the earliest possible date.

The Cayman Islands The Cayman Islands Since February 2021, when the Cayman Islands made a high-level political commitment to work Since February 2021, when the Cayman Islands made a high-level political commitment to work with the FATF and CFATF to strengthen the effectiveness of its AML/CFT regime, the Cayman with the FATF and CFATF to strengthen the effectiveness of its AML/CFT regime, the Cayman Islands has taken steps towards improving its AML/CFT regime, including by imposing adequate Islands has taken steps towards improving its AML/CFT regime, including by imposing adequate and effective sanctions in cases where relevant parties (including legal persons) do not file and effective sanctions in cases where relevant parties (including legal persons) do not file accurate, adequate and up-to-date beneficial ownership information in line with those accurate, adequate and up-to-date beneficial ownership information in line with those requirements. requirements. The Cayman Islands should continue to work on implementing its action plan to The Cayman Islands should continue to work on implementing its action plan to address its strategic deficiencies, including by demonstrating that they are prosecuting all types address its strategic deficiencies, including by demonstrating that they are prosecuting all types of money laundering cases in line with the jurisdiction's risk profile and that such prosecutions of money laundering cases in line with the jurisdiction's risk profile and that such prosecutions are resulting in the application of dissuasive, effective, and proportionate sanctions. are resulting in the application of dissuasive, effective, and proportionate sanctions. The FATF The FATF urges the Cayman Islands to swiftly complete its action plan as all deadlines have now expired urges the Cayman Islands to swiftly complete its action plan as all deadlines have now expired and to address the above-mentioned strategic deficiency by February 2023. and to address the above-mentioned strategic deficiency by February 2023.

The Democratic Republic of the Congo The Democratic Republic of the Congo In October 2022, the DRC made a high-level political commitment to work with the FATF and In October 2022, the DRC made a high-level political commitment to work with the FATF and GABAC to strengthen the effectiveness of its AML/CFT regime. GABAC to strengthen the effectiveness of its AML/CFT regime. Since the adoption of its MER in Since the adoption of its MER in October 2020, the DRC has made progress on some of the MER's recommended actions including October 2020, the DRC has made progress on some of the MER's recommended actions including making confiscation of proceeds of crime a policy priority. making confiscation of proceeds of crime a policy priority. The DRC will work to implement its The DRC will work to implement its FATF action plan by: FATF action plan by: (1) finalising the NRA on ML and TF and adopting an AML/CFT national (1) finalising the NRA on ML and TF and adopting an AML/CFT national strategy; (2) designating supervisory authorities for all DNFBP sectors, and developing and strategy; (2) designating supervisory authorities for all DNFBP sectors, and developing and implementing a risk-based supervision plan; implementing a risk-based supervision plan; (3) adequately resourcing the FIU, and build its (3) adequately resourcing the FIU, and build its capacity to conduct operational and strategic analysis; capacity to conduct operational and strategic analysis; (4) strengthening the capabilities of (4) strengthening the capabilities of authorities involved in the investigation and prosecution of ML and TF; authorities involved in the investigation and prosecution of ML and TF; and (5) demonstrating and (5) demonstrating effective implementation of TF and PF-related TFS. effective implementation of TF and PF-related TFS. ADVISORY Page 819

Gibraltar (Statement from June 2022) NFIU In June 2022, Gibraltar made a high-level political commitment to work with the FATF and In June 2022, Gibraltar made a high-level political commitment to work with the FATF and MONEYVAL to strengthen the effectiveness of its AML/CFT regime. MONEYVAL to strengthen the effectiveness of its AML/CFT regime. Since the adoption of its MER Since the adoption of its MER in December 2019, Gibraltar has made progress on a significant number of its MER'S in December 2019, Gibraltar has made progress on a significant number of its MER'S recommended actions, such as completing a new national risk assessment, addressing the recommended actions, such as completing a new national risk assessment, addressing the technical deficiencies in relation to BO-related record keeping, introducing transparency technical deficiencies in relation to BO-related record keeping, introducing transparency requirements for nominee shareholders and directors, strengthening the financial intelligence requirements for nominee shareholders and directors, strengthening the financial intelligence unit, and refining its ML investigation policy in line with risks. unit, and refining its ML investigation policy in line with risks. Gibraltar should work on Gibraltar should work on implementing its action plan, including by: implementing its action plan, including by: (1) ensuring that supervisory authorities for non-bank (1) ensuring that supervisory authorities for non-bank financial institutions and DNFBPs use a range of effective, proportionate, and dissuasive sanctions financial institutions and DNFBPs use a range of effective, proportionate, and dissuasive sanctions for AML/CFT breaches; and (2) demonstrating that it is more actively and successfully pursuing for AML/CFT breaches; and (2) demonstrating that it is more actively and successfully pursuing final confiscation judgements, through criminal or civil proceedings based on financial final confiscation judgements, through criminal or civil proceedings based on financial investigations. investigations. Haiti In June 2021, Haiti made a high-level political commitment to work with the FATF and CFATF In June 2021, Haiti made a high-level political commitment to work with the FATF and CFATF to strengthen the effectiveness of its AML/CFT regime. to strengthen the effectiveness of its AML/CFT regime. Haiti will work to implement its action Haiti will work to implement its action plan, including by: plan, including by: (1) developing its ML/TF risk assessment process and disseminating the (1) developing its ML/TF risk assessment process and disseminating the findings; (2) facilitating information