Advisory on the FATF-Identified Jurisdictions with AML/CFT Deficiencies

FIN-2017-A005 September 15, 2017
Advisory on the FATF-Identified Jurisdictions with AML/CFT Deficiencies On June 23, 2017, the Financial Action Task Force (FATF) updated its list of jurisdictions with strategic anti-money laundering and combatting the financing of terrorism (AML/ CFT) deficiencies. The changes may affect U.S. financial institutions’ obligations and risk-based approaches with respect to relevant jurisdictions. As part of the FATF’s listing and monitoring process to ensure compliance with its international AML/CFT standards, the FATF identifies certain jurisdictions as having strategic deficiencies in their AML/CFT regimes.1

1. The FATF (www.fatf-gafi.org) is a 37-member intergovernmental body that establishes international standards to
   combat money laundering and counter the financing of terrorism and proliferation of weapons of mass destruction. The United States is a member of the FATF. These jurisdictions appear in two documents: (i) the “FATF Public Statement,” which includes jurisdictions that are subject to the FATF’s call for countermeasures or are subject to enhanced due diligence (EDD) due to their strategic AML/CFT deficiencies, and (ii) “Improving Global AML/CFT Compliance: On-going Process,” which includes jurisdictions identified by the FATF as having strategic AML/CFT deficiencies.2
2. The FATF public identification of countries with strategic AML/CFT deficiencies is in response to the G-20
   leaders’ call for the FATF to reinvigorate its process for assessing countries’ compliance with international AML/ CFT standards. The G-20 leaders have consistently called for the FATF to issue regular updates on jurisdictions with strategic deficiencies. Specifically within the FATF, the International Cooperation Review Group (ICRG) monitors and identifies countries with AML/CFT deficiencies. For more information on the ICRG procedures, please visit the FATF’s website – www.fatf-gafi.org/topics/high-riskandnon-cooperativejurisdictions/documents/ moreabouttheinternationalco-operationreviewgroupicrg.html. On June 23, 2017, the FATF updated both documents with the concurrence of the United States. Financial institutions should consider these changes when reviewing their obligations and risk-based policies, procedures, and practices with respect to the jurisdictions noted below.3
3. 31 U.S.C. § 5318(h) and (i).
   FATF “Public Statement”:

• Democratic People’s Republic of Korea (DPRK) and Iran
  FATF “Improving Global AML/CFT Compliance: On-going Process”:
• Bosnia and Herzegovina, Ethiopia, Iraq, Syria, Uganda, Vanuatu, and Yemen