2025-07-24

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Circular Letter No. CC/2025/00000016

The document requires credit institutions, financial companies, payment institutions, electronic money institutions, and virtual asset entities to maintain countermeasures against North Korea and Iran, and to apply enhanced identification and due diligence measures to transactions involving North Korea, Iran, and Myanmar. It also mandates risk-proportionate enhanced measures for jurisdictions under increased monitoring, specifically noting the inclusion of Bolivia and the British Virgin Islands and the exclusion of Croatia, Mali, and Tanzania from that list. These obligations are based on the FATF's June 12-13, 2025 plenary meeting outcomes and apply to business relationships, occasional transactions, and operations with entities resident or established in the identified jurisdictions.

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Circular Letter No. CC/2025/00000016 Sent to: Credit Institutions, Financial Companies, Payment Institutions, Electronic Money Institutions and entities carrying out activities with virtual assets. Mod. 99999924/T – 01/14 Subject: Disclosure of FATF communications (June 2025 plenary meeting)

I. COMMUNICATIONS ISSUED BY THE FATF With the aim of protecting the international financial system from the risks associated with money laundering and terrorist financing, as well as to foster adequate compliance with AML/CFT standards, the FINANCIAL ACTION TASK FORCE (FATF) acts to identify jurisdictions presenting strategic deficiencies in money laundering and terrorist financing prevention and to develop coordinated and decisive responses worldwide to combat these realities.

Following the plenary meeting held between June 12 and 13, 2025, the FATF released the following documents:

• HIGH-RISK JURISDICTIONS SUBJECT TO A CALL FOR ACTION, dated June 13, 2025, which identifies jurisdictions subject to countermeasures and jurisdictions with strategic deficiencies in money laundering and terrorist financing prevention that have not made sufficient progress in overcoming these deficiencies and/or have not agreed with the FATF on an action plan for this purpose. The full content of this document can be consulted at: High-Risk Jurisdictions subject to a Call for Action - 13 June 2025.

• JURISDICTIONS UNDER INCREASED MONITORING, dated June 13, 2025, which identifies jurisdictions with strategic deficiencies in money laundering and terrorist financing prevention that have developed an action plan to overcome them and are subject to a monitoring process by the FATF. The full content of this document can be consulted at: Jurisdictions under Increased Monitoring - 13 June 2025.

Regarding these documents, the following should be noted:

a) Regarding the list of High-Risk Jurisdictions Subject to a Call for Action: • The FATF reiterates its call for the application of countermeasures against the Democratic People's Republic of Korea (North Korea) and the Islamic Republic of Iran, highlighting an increased risk of proliferation financing (“Given heightened proliferation financing risks, the FATF reiterates its call to apply countermeasures on these high-risk jurisdictions.”). • The Republic of the Union of Myanmar remains in the category of jurisdictions subject to the application of enhanced identification and due diligence measures proportional to the risks arising from them, with the FATF reiterating that if no progress is made by October 2025, countermeasures will be considered.

Mod. 99999924/T – 01/14

b) Regarding the list of Jurisdictions Under Increased Monitoring: • Since February 2025, the FATF has assessed the progress of 19 jurisdictions, and their respective statements have been updated; • Regarding the People's Democratic Republic of Algeria, the Lebanese Republic, Nepal, the Syrian Arab Republic, the Republic of Yemen, and the Lao People's Democratic Republic, previous FATF statements were included in this document, but these may not reflect the current state of their respective money laundering and terrorist financing prevention regimes; • Two new jurisdictions have been identified and included: the Plurinational State of Bolivia and the British Virgin Islands; • It is noted that three jurisdictions have exited: the Republic of Croatia, the Republic of Mali, and the United Republic of Tanzania.

Furthermore, it is important to note the continued maintenance of the suspension of the membership status of the Russian Federation.

II. Comparative framework with communications issued by the FATF in February 2025

HIGH-RISK JURISDICTIONS SUBJECT TO A CALL FOR ACTIONJURISDICTIONS UNDER INCREASED MONITORING
Jurisdictions subject to the application of countermeasuresJurisdictions subject to the application of enhanced measures

PLENARY MEETING 12-13 June 2025 Democratic People's Republic of Korea (North Korea) | Islamic Republic of Iran; Republic of the Union of Myanmar | Republic of South Africa; Republic of Angola; People's Democratic Republic of Algeria; Plurinational State of Bolivia; Republic of Bulgaria; Burkina Faso; Republic of Cameroon; Democratic Republic of the Congo; Republic of Côte d'Ivoire; Republic of Haiti; Republic of Yemen; British Virgin Islands; Lao People's Democratic Republic; Lebanese Republic; Republic of Mozambique; Principality of Monaco; Republic of Namibia; Nepal; Federal Republic of Nigeria; Republic of Kenya; Syrian Arab Republic; Republic of South Sudan; Bolivarian Republic of Venezuela; Socialist Republic of Vietnam | Republic of Croatia; Republic of Mali; United Republic of Tanzania

PLENARY MEETING 19-21 February 2025 Democratic People's Republic of Korea (North Korea) | Islamic Republic of Iran; Republic of the Union of Myanmar | Republic of South Africa; Republic of Angola; People's Democratic Republic of Algeria; Republic of Bulgaria; Burkina Faso; Republic of Cameroon; Democratic Republic of the Congo; Republic of Côte d'Ivoire; Republic of Croatia; Republic of Haiti; Republic of Yemen; Lao People's Democratic Republic; Lebanese Republic; Republic of Mali; Republic of Mozambique; Principality of Monaco; Republic of Namibia; Nepal; Federal Republic of Nigeria; Republic of Kenya; Syrian Arab Republic; Republic of South Sudan; United Republic of Tanzania; Bolivarian Republic of Venezuela; Socialist Republic of Vietnam | Republic of the Philippines

II. PROCEDURES AND MEASURES TO BE ADOPTED BY INSTITUTIONS Given the content of the documents produced by the FATF and within the scope of the duty to disseminate information to which supervisory authorities are bound (Article 120 of Law No. 83/2017, of August 18 - “Law No. 83/2017”), the Bank of Portugal informs the following, regarding business relationships, occasional transactions, and operations carried out with persons, entities, and unincorporated collective interest centers1 residing or established in the jurisdictions identified below:

a. Considering the existence of a very high risk of money laundering, terrorist financing, and proliferation of weapons of mass destruction, it is determined, under the terms and for the purposes of paragraph 1(b) of Article 99 of Law No. 83/2017, the maintenance of countermeasures, proportional to those risks, with respect to the DEMOCRATIC PEOPLE'S REPUBLIC OF KOREA (NORTH KOREA) and the ISLAMIC REPUBLIC OF IRAN, which must in any case include the countermeasures identified in the High-Risk Jurisdictions Subject to a Call For Action and in paragraphs (f) to (h) and (k) of paragraph 3 of Article 99 of the aforementioned Law No. 83/2017.

b. Under paragraph 2 of Article 36 and paragraph 3(b) of Article 37 of Law No. 83/2017, enhanced identification and due diligence measures shall continue to be adopted – including necessarily the measures specified in the High-Risk Jurisdictions Subject to a Call For Action – and all business relationships, occasional transactions, and operations involving the DEMOCRATIC PEOPLE'S REPUBLIC OF KOREA (NORTH KOREA), the ISLAMIC REPUBLIC OF IRAN, or the REPUBLIC OF THE UNION OF MYANMAR shall be examined with special care.

c. Regarding business relationships, occasional transactions, and operations involving jurisdictions subject to a monitoring process, or other high-risk third countries that are part of Delegated Regulation (EU) 2016/1675 of the Commission, of July 14, 2016, in its currently valid version, enhanced measures that are proportional to the specifically identified risk shall be adopted, without prejudice to the above, under the provisions of paragraph 2 of Article 36, and paragraph 1 and paragraph 3(b) of Article 37, all of the aforementioned Law No. 83/2017.


Supplementary information regarding the conclusions of the FATF plenary meeting can be obtained on the website www.fatf-gafi.org.

1 Including their respective representatives and beneficial owners.

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