Regulatory Alerts2011-04-20 | Circular 03/2011 (GW)BaFin Circular 03/2011 (GW) – FATF Updates on Iran, North Korea and AML/CFT Compliance
BaFin issues Circular 03/2011 to implement the FATF’s February 2011 updates, reclassifying Iran and North Korea into Category 1 for targeted counter-measures against money laundering and terrorist financing risks. Financial institutions must apply the same enhanced due diligence measures to North Korea as previously mandated for Iran, while maintaining adequate risk assessments for Category 2 jurisdictions showing unconfirmed progress. The circular clarifies that although enhanced due diligence is not strictly mandatory for the latter group, regulated entities must explicitly factor their specific risk profiles into ongoing AML/CFT compliance procedures.
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