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2024-01-01

Decision No. 2 of 2024 on High-Risk and Enhanced Monitoring Countries

The Palestine Monetary Authority’s Financial Follow-Up Unit issued Decision No. 2 of 2024 to update the lists and compliance requirements for High-Risk (Black List) and Enhanced Monitoring (Grey List) countries in accordance with FATF standards. The decision mandates Palestinian financial institutions and designated non-financial businesses and professions to apply risk-based enhanced due diligence, targeted financial sanctions, and specific operational restrictions for North Korea, Iran, and Myanmar, while revising the Grey List by adding Monaco and Venezuela and removing Turkey and Jamaica. All regulated entities must integrate these country-specific AML/CFT deficiency assessments into their self-evaluations and implement the updated measures effective upon circulation.

Palestine

Palestine Monetary Authority

[Logo of Palestine Monetary Authority]

Palestine Monetary Authority PALESTINE MONETARY AUTHORITY

Circular No. (18/2024) To all licensed money changers operating in Palestine Date: Wednesday, 03 July 2024

Subject: High-Risk Countries and Enhanced Monitoring Countries

Attached is a copy of the Decision issued by the Financial Follow-Up Unit No. (2024/2) dated 30 June 2024 regarding High-Risk Countries and Enhanced Monitoring Countries in accordance with the list issued by the Financial Action Task Force (FATF). Accordingly, legal measures required to implement the aforementioned Decision and related measures are requested, with emphasis on compliance with the following:

Considering concerns regarding deficiencies in Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) systems of countries classified on the "Grey List" (Enhanced Monitoring Countries), when conducting and updating self-assessments of AML/CFT risks.
Applying the Risk-Based Approach (RBA), such that due diligence measures are proportionate to (risk analysis results, nature of financial transaction risks, customer risks, and country classifications), with enhanced due diligence measures applied when high risks are identified.

Supervisory Group Palestine Monetary Authority

Copy: The respected Financial Follow-Up Unit

Financial Follow-Up Unit State of Palestine

وحدة المتابعة المالية dولة فلسطين

Decision No. (2024/2) Issued by the Financial Follow-Up Unit Dated 30 June 2024

Regarding the Lists of High-Risk Countries and Enhanced Monitoring Countries

Based on the provisions of Law No. (39) of 2022 regarding Anti-Money Laundering and Counter-Terrorist Financing and its amendments, particularly Articles (20) and paragraphs (3, 4) of Article (30), and in accordance with the National Committee for AML/CFT Decision No. (8/G/2016) dated 01 December 2016, regarding the delegation to the Financial Follow-Up Unit to publish the list of high-risk countries issued periodically by FATF, and subsequently as determined by the Group since 21 February 2020 through 28 June 2024, and further to the National Committee Decision No. (T/2020/5) dated 24 February 2020 regarding High-Risk and Enhanced Monitoring Countries, and subsequently to the Financial Follow-Up Unit Decision No. (2020/1) dated 25 February 2020 and subsequent decisions regarding the lists of High-Risk and Enhanced Monitoring Countries. In light of public interest requirements, it is decided as follows:

First High-Risk Countries List (Black List)

All financial institutions, designated non-financial businesses and professions (DNFBPs) in Palestine must continue to apply the following measures regarding high-risk countries:

Country	Required Measures Regarding Countries
Democratic People's Republic of Korea (North Korea).	1. Apply targeted financial sanctions in accordance with Executive Order No. (2022/14) regarding the implementation of Security Council resolutions.
Islamic Republic of Iran (Iran).	2. Pay special attention to commercial relations and transactions with those countries, including financial companies and institutions, and apply the following countermeasures: <br> a. Apply enhanced due diligence measures to business relations and transactions with those countries (as part of countermeasures), proportionate to the arising risks, according to Articles (26, 27) of National Committee Instructions No. (4) of 2022 for financial institutions, and Articles (24, 25) of National Committee Instructions No. (3) of 2022 for DNFBPs.

Country

Required Measures Regarding Countries

Democratic People's Republic of Korea (North Korea).

1. Apply targeted financial sanctions in accordance with Executive Order No. (2022/14) regarding the implementation of Security Council resolutions.

Islamic Republic of Iran (Iran).

2. Pay special attention to commercial relations and transactions with those countries, including financial companies and institutions, and apply the following countermeasures: a. Apply enhanced due diligence measures to business relations and transactions with those countries (as part of countermeasures), proportionate to the arising risks, according to Articles (26, 27) of National Committee Instructions No. (4) of 2022 for financial institutions, and Articles (24, 25) of National Committee Instructions No. (3) of 2022 for DNFBPs.

b. Apply the enhanced due diligence measures mentioned in paragraph (a) of this item when dealing with any entity acting on behalf of a natural or legal person, including financial companies operating in those countries. c. Enhance the reporting mechanisms adopted by the financial institution or DNFBP, including increasing cooperation among staff and promptly providing data to the AML/CFT compliance officer within the institution, to ensure no transactions suspected of involving money laundering or related crimes or terrorist financing are executed, and immediately report such suspicions to the Unit without delay, providing all data related to the attempted transactions, while ensuring reporting confidentiality and non-disclosure to the client. d. Do not establish branches, representative offices, or subsidiaries in those countries. e. Do not rely on third parties located in those countries for any due diligence measures regarding customers. f. Do not establish any correspondent banking or similar correspondent relationships with financial institutions in those countries.

Country	Required Measures Regarding Countries
Union of Myanmar (Myanmar).	1. Apply enhanced due diligence measures to business relations and transactions with Myanmar, proportionate to the risks arising in the country, according to Articles (26, 27) of National Committee Instructions No. (4) of 2022 for financial institutions, and Articles (24, 25) of National Committee Instructions No. (3) of 2022 for DNFBPs. <br> 2. When applying enhanced due diligence measures, ensure that fund flows for humanitarian assistance and legitimate non-profit organization activities and financial transfers are not disrupted.

Country

Required Measures Regarding Countries

Union of Myanmar (Myanmar).

1. Apply enhanced due diligence measures to business relations and transactions with Myanmar, proportionate to the risks arising in the country, according to Articles (26, 27) of National Committee Instructions No. (4) of 2022 for financial institutions, and Articles (24, 25) of National Committee Instructions No. (3) of 2022 for DNFBPs. 2. When applying enhanced due diligence measures, ensure that fund flows for humanitarian assistance and legitimate non-profit organization activities and financial transfers are not disrupted.

Second Enhanced Monitoring Countries List (Grey List)

The list of Enhanced Monitoring Countries specified in Unit Decision No. (2024/1) is amended by adding (Monaco, Venezuela), and removing (Republic of Turkey, Jamaica), resulting in the list as shown in the table below. Concerns regarding deficiencies in AML/CFT systems for these countries (according to the attached annex) must be considered when conducting self-assessments of AML/CFT risks, including identifying, analyzing, and evaluating those risks.

No.	Country Name	No.	Country Name
1	Bulgaria	12	Republic of Nigeria
2	Burkina Faso	13	Republic of the Philippines
3	Cameroon	14	Republic of Senegal
4	Croatia	15	Republic of South Africa
5	Democratic Republic of the Congo	16	Republic of South Sudan
6	Republic of Haiti	17	Syrian Arab Republic (Syria)
8	Republic of Mali	19	Venezuela
9	Monaco	20	Vietnam
10	Republic of Mozambique	21	Republic of Yemen (Yemen)
11	Republic of Namibia	-	-

Third Implementation

All financial institutions and designated non-financial businesses and professions must implement the provisions of this Decision, which shall take effect from the date of its circulation.

Head of Financial Follow-Up Unit Dr. Firas Marar [Signature and Seal]

Risks Related to Deficiencies in AML/CFT Systems

Attached to Financial Follow-Up Unit Decision No. (2024/2) Regarding the lists of High-Risk Countries and Enhanced Monitoring Countries

Risks Related to Deficiencies in AML/CFT Systems in Countries

Section One: Deficiencies through Assessment Reports (for all countries): This section explains how to access risks related to AML/CFT and Combating the Financing of Proliferation (CFP) systems for countries on the Grey List, as well as all other countries subject to mutual evaluation by FATF or peer groups. These risks can be accessed by reviewing the Mutual Evaluation Reports (MERs) related to those countries, and subsequent follow-up reports. The published MERs and follow-up reports on the FATF or MENAFATF websites contain all deficiencies and key conclusions regarding AML/CFT systems for countries on the Enhanced Monitoring list and other evaluated countries, accessible as follows:

a. Accessing MERs in English (for all countries).

Enter the website: www.fatf-gafi.org
Select (publications) then (publications).
From the Topics list, select (Mutual Evaluations).
Search for the country name in English on the search window shown in the adjacent figure.

b. Accessing MERs in Arabic (for countries evaluated by MENAFATF).

Enter the website: www.menafatf.org/ar
Select (Mutual Evaluation) then (Evaluation Reports - Second Round of Evaluation), or follow-up reports.
Select the report from the list appearing by country name.

Attached to Financial Follow-Up Unit Decision No. (2024/2) Regarding the lists of High-Risk Countries and Enhanced Monitoring Countries

Section Two: Implementation of Action Plans to Address Deficiencies Countries on the Grey List have made high-level political commitments to address strategic deficiencies in AML/CFT systems, and continue to implement their commitments to address any deficiencies. The items below outline the core areas those countries are addressing or have addressed, based on specific deficiencies identified in MERs and follow-up reports. These must be considered whether negative or positive:

Country	Core Areas
Bulgaria	Since October 2023, when Bulgaria made a high-level political commitment to work with the FATF and MONEYVAL to strengthen the effectiveness of its AML/CFT regime, Bulgaria has taken steps towards improving its AML/CFT regime, including by adopting an action plan to implement its national AML/CFT Strategy, establishing market entry controls for VASPs and postal money operators, communicating UN changes to targeted financial sanctions (TFS) and completing the implementation of a system to ensure prioritisation of STRs. Bulgaria should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) demonstrating initial implementation of its national action plan for its AML/CFT Strategy; (2) addressing the remaining technical compliance deficiencies; (3) demonstrating initial implementation of risk-based supervision for postal money operators, currency exchange providers and real estate agents; (4) ensuring that the beneficial ownership information held in the Register is accurate and up-to-date; (5) improving investigations and prosecutions of different types of money laundering in line with risks, including high-scale corruption and organised crime; (6) ensuring that confiscation is pursued as a policy objective; (7) ensuring the ability to conduct parallel financial investigations in all terrorism investigations; (8) addressing gaps in the PF TFS frameworks; and (9) identifying the subset of non-profit organisations (NPOs) most vulnerable to TF abuse and demonstrating initial implementation of risk-based monitoring to prevent abuse for TF purposes.
Burkina Faso	Since February 2021, when 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 towards improving its AML/CFT regime, including by implementing a case management system for mutual legal assistance requests, developing a software for the management of STRs and establishing procedures for the implementation of the cross-border declaration system. Burkina Faso should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) strengthening resource capacities of all AML/CFT supervisory authorities and implementing risk-based supervision; (2) maintaining comprehensive and updated basic and beneficial ownership information of legal persons and strengthening the system of sanctions for violations of transparency obligations; and (3) implementing an effective TFS regime related to TF and PF as well as risk-based monitoring and supervision of NPOs.

Country

Core Areas

Bulgaria

Since October 2023, when Bulgaria made a high-level political commitment to work with the FATF and MONEYVAL to strengthen the effectiveness of its AML/CFT regime, Bulgaria has taken steps towards improving its AML/CFT regime, including by adopting an action plan to implement its national AML/CFT Strategy, establishing market entry controls for VASPs and postal money operators, communicating UN changes to targeted financial sanctions (TFS) and completing the implementation of a system to ensure prioritisation of STRs. Bulgaria should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) demonstrating initial implementation of its national action plan for its AML/CFT Strategy; (2) addressing the remaining technical compliance deficiencies; (3) demonstrating initial implementation of risk-based supervision for postal money operators, currency exchange providers and real estate agents; (4) ensuring that the beneficial ownership information held in the Register is accurate and up-to-date; (5) improving investigations and prosecutions of different types of money laundering in line with risks, including high-scale corruption and organised crime; (6) ensuring that confiscation is pursued as a policy objective; (7) ensuring the ability to conduct parallel financial investigations in all terrorism investigations; (8) addressing gaps in the PF TFS frameworks; and (9) identifying the subset of non-profit organisations (NPOs) most vulnerable to TF abuse and demonstrating initial implementation of risk-based monitoring to prevent abuse for TF purposes.

Burkina Faso

Since February 2021, when 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 towards improving its AML/CFT regime, including by implementing a case management system for mutual legal assistance requests, developing a software for the management of STRs and establishing procedures for the implementation of the cross-border declaration system. Burkina Faso should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) strengthening resource capacities of all AML/CFT supervisory authorities and implementing risk-based supervision; (2) maintaining comprehensive and updated basic and beneficial ownership information of legal persons and strengthening the system of sanctions for violations of transparency obligations; and (3) implementing an effective TFS regime related to TF and PF as well as risk-based monitoring and supervision of NPOs.

Attached to Financial Follow-Up Unit Decision No. (2024/2) Regarding the lists of High-Risk Countries and Enhanced Monitoring Countries

The FATF notes Burkina Faso’s continued progress across its action plan, however all deadlines have expired and work remains. The FATF urges Burkina Faso to swiftly implement its action plan to address the above-mentioned strategic deficiencies as soon as possible as all deadlines expired in December 2022.

Country	Core Areas
Cameroon	In June 2023, Cameroon made a high-level political commitment to work with the FATF and GABAC to strengthen the effectiveness of its AML/CFT regime. Cameroon should continue working on implementing its action plan to address its strategic deficiencies, including by work to implement its FATF action plan by: (1) aligning AML/CFT national strategies and policies with the findings of the NRA and monitoring their implementation, and demonstrating AML/CFT cooperation and coordination between competent authorities; (2) ensuring risk-based prioritisation of incoming international cooperation requests in line with risks and responding in an effective manner; (3) enhancing risk-based supervision of banks and implementing effective risk-based supervision for non-bank FIs and DNFBPs, and conducting appropriate outreach to high-risk FIs and DNFBPs; (4) maintaining and ensuring timely access by competent authorities to adequate and up to date beneficial ownership information on legal persons, and establishing a sanctions regime for violations of transparency obligations applicable to legal persons; (5) enhancing secure information exchange between the FIU, reporting entities and competent authorities and demonstrating an increase in dissemination of intelligence reports to support operational needs of competent authorities; (6) demonstrating that authorities are able to conduct a range of ML investigations, and prosecute ML in line with risks; (7) implementing policies and procedures for seizing and confiscating proceeds and instrumentalities of crime and managing frozen, seized and confiscated property, and prioritising seizure and confiscation of assets at the border; (8) demonstrating that TF investigations and prosecutions are pursued in line with risk; and (9) demonstrating effective implementation of TF and PF TFS regimes and implementing a risk-based approach to NPOs without disrupting legitimate NPO activities.
Croatia	Since June 2023, when Croatia made a high-level political commitment to work with the FATF and MONEYVAL to strengthen the effectiveness of its AML/CFT regime, Croatia has taken steps towards improving its AML/CFT regime, including demonstrating the ability to systematically detect and where relevant investigate TF in line with its risk profile, addressing technical compliances deficiencies in relation to Recommendations 6 and 7, providing guidance to reporting entities on TFS, and identifying the subset of NPOs most vulnerable to TF abuse. Croatia should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) increasing FIU human resources and improving analytical capabilities; (2) continuing to improve law enforcement authorities' (LEAs') detection, investigation and prosecution of different types of ML, including ML involving a foreign predicate offences and the misuse of legal persons; (3) demonstrating a sustained increase in the application of provisional measures in securing direct/indirect proceeds, as well as foreign proceeds subject to confiscation; (4) demonstrating immediate communication of changes in UN TFS regimes to reporting entities and (5) providing targeted outreach to NPOs and to the donor community on potential vulnerabilities of NPOs to TF abuse.

Country

Core Areas

Cameroon

In June 2023, Cameroon made a high-level political commitment to work with the FATF and GABAC to strengthen the effectiveness of its AML/CFT regime. Cameroon should continue working on implementing its action plan to address its strategic deficiencies, including by work to implement its FATF action plan by: (1) aligning AML/CFT national strategies and policies with the findings of the NRA and monitoring their implementation, and demonstrating AML/CFT cooperation and coordination between competent authorities; (2) ensuring risk-based prioritisation of incoming international cooperation requests in line with risks and responding in an effective manner; (3) enhancing risk-based supervision of banks and implementing effective risk-based supervision for non-bank FIs and DNFBPs, and conducting appropriate outreach to high-risk FIs and DNFBPs; (4) maintaining and ensuring timely access by competent authorities to adequate and up to date beneficial ownership information on legal persons, and establishing a sanctions regime for violations of transparency obligations applicable to legal persons; (5) enhancing secure information exchange between the FIU, reporting entities and competent authorities and demonstrating an increase in dissemination of intelligence reports to support operational needs of competent authorities; (6) demonstrating that authorities are able to conduct a range of ML investigations, and prosecute ML in line with risks; (7) implementing policies and procedures for seizing and confiscating proceeds and instrumentalities of crime and managing frozen, seized and confiscated property, and prioritising seizure and confiscation of assets at the border; (8) demonstrating that TF investigations and prosecutions are pursued in line with risk; and (9) demonstrating effective implementation of TF and PF TFS regimes and implementing a risk-based approach to NPOs without disrupting legitimate NPO activities.

Croatia

Since June 2023, when Croatia made a high-level political commitment to work with the FATF and MONEYVAL to strengthen the effectiveness of its AML/CFT regime, Croatia has taken steps towards improving its AML/CFT regime, including demonstrating the ability to systematically detect and where relevant investigate TF in line with its risk profile, addressing technical compliances deficiencies in relation to Recommendations 6 and 7, providing guidance to reporting entities on TFS, and identifying the subset of NPOs most vulnerable to TF abuse. Croatia should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) increasing FIU human resources and improving analytical capabilities; (2) continuing to improve law enforcement authorities' (LEAs') detection, investigation and prosecution of different types of ML, including ML involving a foreign predicate offences and the misuse of legal persons; (3) demonstrating a sustained increase in the application of provisional measures in securing direct/indirect proceeds, as well as foreign proceeds subject to confiscation; (4) demonstrating immediate communication of changes in UN TFS regimes to reporting entities and (5) providing targeted outreach to NPOs and to the donor community on potential vulnerabilities of NPOs to TF abuse.

Attached to Financial Follow-Up Unit Decision No. (2024/2) Regarding the lists of High-Risk Countries and Enhanced Monitoring Countries

Country	Core Areas
The Democratic Republic of the Congo	Since October 2022, when the DRC made a high-level political commitment to work with the FATF and GABAC to strengthen the effectiveness of its AML/CFT regime, the DRC has taken steps towards improving its AML/CFT regime, including by disseminating the results of their NRA and providing financial and human resources to FI and DNFBP supervisors. The DRC should continue to work to implement its FATF action plan to address its strategic deficiencies, including by: (1) developing and implementing a risk-based supervision plan; (2) building the capacity of the FIU to conduct operational and strategic analysis; (3) strengthening the capabilities of authorities involved in the investigation and prosecution of ML and TF; and (4) demonstrating effective implementation of TF and PF-related TFS.
Haiti	Since June 2021, when Haiti made a high-level political commitment to work with the FATF and CFATF to strengthen the effectiveness of its AML/CFT regime, Haiti has taken steps towards improving its AML/CFT regime, including improving the FIU's access to and use of a wide range of information in its financial intelligence products through the adoption of a new organic law. The FATF recognises the political commitment expressed at a high level and the efforts demonstrated by Haiti to advance its commitments in the midst of the challenging social, economic and security situation within the country. Haiti should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) completing its ML/TF risk assessment process and disseminating the findings; (2) implementing risk-based AML/CFT supervision for all financial institutions and DNFBPs deemed to constitute a higher ML/TF risk; (3) ensuring basic and beneficial ownership information are maintained and accessible in a timely manner; (4) ensuring the FIU has adequate resources and processes to produce and disseminate operational and strategic analysis to competent authorities for combatting ML and TF; (4) demonstrating authorities are identifying, investigating and prosecuting ML cases in a manner consistent with Haiti's risk profile; (5) demonstrating an increase of identification, tracing and recovery of proceeds of crimes; (6) conducting appropriate risk-based monitoring of NPOs vulnerable to TF abuse without disrupting or discouraging legitimate NPO activities. <br> The FATF notes Haiti's continued progress across its action plan, however all deadlines are expired and work remains. The FATF encourages Haiti to continue to implement its action plan to address the above-mentioned strategic deficiencies.

Country

Core Areas

The Democratic Republic of the Congo

Since October 2022, when the DRC made a high-level political commitment to work with the FATF and GABAC to strengthen the effectiveness of its AML/CFT regime, the DRC has taken steps towards improving its AML/CFT regime, including by disseminating the results of their NRA and providing financial and human resources to FI and DNFBP supervisors. The DRC should continue to work to implement its FATF action plan to address its strategic deficiencies, including by: (1) developing and implementing a risk-based supervision plan; (2) building the capacity of the FIU to conduct operational and strategic analysis; (3) strengthening the capabilities of authorities involved in the investigation and prosecution of ML and TF; and (4) demonstrating effective implementation of TF and PF-related TFS.

Haiti

Since June 2021, when Haiti made a high-level political commitment to work with the FATF and CFATF to strengthen the effectiveness of its AML/CFT regime, Haiti has taken steps towards improving its AML/CFT regime, including improving the FIU's access to and use of a wide range of information in its financial intelligence products through the adoption of a new organic law. The FATF recognises the political commitment expressed at a high level and the efforts demonstrated by Haiti to advance its commitments in the midst of the challenging social, economic and security situation within the country. Haiti should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) completing its ML/TF risk assessment process and disseminating the findings; (2) implementing risk-based AML/CFT supervision for all financial institutions and DNFBPs deemed to constitute a higher ML/TF risk; (3) ensuring basic and beneficial ownership information are maintained and accessible in a timely manner; (4) ensuring the FIU has adequate resources and processes to produce and disseminate operational and strategic analysis to competent authorities for combatting ML and TF; (4) demonstrating authorities are identifying, investigating and prosecuting ML cases in a manner consistent with Haiti's risk profile; (5) demonstrating an increase of identification, tracing and recovery of proceeds of crimes; (6) conducting appropriate risk-based monitoring of NPOs vulnerable to TF abuse without disrupting or discouraging legitimate NPO activities. The FATF notes Haiti's continued progress across its action plan, however all deadlines are expired and work remains. The FATF encourages Haiti to continue to implement its action plan to address the above-mentioned strategic deficiencies.

Attached to Financial Follow-Up Unit Decision No. (2024/2) Regarding the lists of High-Risk Countries and Enhanced Monitoring Countries

Country	Core Areas
Kenya	(Statement from February 2024) <br> In February 2024, Kenya made a high-level political commitment to work with the FATF and ESAAMLG to strengthen the effectiveness of its AML/CFT regime. Since the adoption of its MER in September 2022, Kenya has made progress on some of the MER's recommended actions including by making amendments to its AML/CFT legislation to bring its framework in closer compliance with the FATF recommendations and establishing a case management system to better manage its international cooperation requests. Kenya will work to implement its FATF action plan by: (1) completing a TF risk assessment and presenting the results of the NRA and other risk assessments in a consistent manner to competent authorities and the private sector and updating the national AML/CFT strategies; (2) improving risk-based AML/CFT supervision of FIs and DNFBPs and adopting a legal framework for the licensing and supervision of VASPs; (3) enhancing the understanding of preventive measures by FIs and DNFBPs, including to increase STR filing and implement TFS without delay; (4) designating an authority for the regulation of trusts and collection of accurate and up-to-date beneficial ownership information and implementing remedial actions for breaches of compliance with transparency requirements for legal persons and arrangements; (5) improving the use and quality of financial intelligence products; (6) increasing ML and TF investigations and prosecutions in line with risks; (7) bringing the TFS in compliance with R.6 and R.7 and ensure its effective implementation; and (8) revising the framework for NPO regulation and oversight to ensure that mitigating measures are risk-based and do not disrupt or discourage legitimate NPO activity.
Mali	Since October 2021, when Mali made a high-level political commitment to work with the FATF and GIABA to strengthen the effectiveness of its AML/CFT regime, Mali has taken steps towards improving its AML/CFT regime, including by establishing a framework for the monitoring of NPOs at risk of abuse for TF purposes and implementing measures commensurate with the risk. Mali should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) demonstrating timely access to accurate beneficial ownership information; (2) addressing pending technical compliance deficiencies with R.5 and 20, and identifying and investigating TF activities in line with the country's risk profile; and (3) implementing TFS related to TF and PF. <br> The FATF notes Mali's continued progress across its action plan, however all deadlines have now expired and work remains. The FATF encourages Mali to continue to implement its action plan to address the above-mentioned strategic deficiencies as soon as possible.

Country

Core Areas

Kenya

(Statement from February 2024) In February 2024, Kenya made a high-level political commitment to work with the FATF and ESAAMLG to strengthen the effectiveness of its AML/CFT regime. Since the adoption of its MER in September 2022, Kenya has made progress on some of the MER's recommended actions including by making amendments to its AML/CFT legislation to bring its framework in closer compliance with the FATF recommendations and establishing a case management system to better manage its international cooperation requests. Kenya will work to implement its FATF action plan by: (1) completing a TF risk assessment and presenting the results of the NRA and other risk assessments in a consistent manner to competent authorities and the private sector and updating the national AML/CFT strategies; (2) improving risk-based AML/CFT supervision of FIs and DNFBPs and adopting a legal framework for the licensing and supervision of VASPs; (3) enhancing the understanding of preventive measures by FIs and DNFBPs, including to increase STR filing and implement TFS without delay; (4) designating an authority for the regulation of trusts and collection of accurate and up-to-date beneficial ownership information and implementing remedial actions for breaches of compliance with transparency requirements for legal persons and arrangements; (5) improving the use and quality of financial intelligence products; (6) increasing ML and TF investigations and prosecutions in line with risks; (7) bringing the TFS in compliance with R.6 and R.7 and ensure its effective implementation; and (8) revising the framework for NPO regulation and oversight to ensure that mitigating measures are risk-based and do not disrupt or discourage legitimate NPO activity.

Mali

Since October 2021, when Mali made a high-level political commitment to work with the FATF and GIABA to strengthen the effectiveness of its AML/CFT regime, Mali has taken steps towards improving its AML/CFT regime, including by establishing a framework for the monitoring of NPOs at risk of abuse for TF purposes and implementing measures commensurate with the risk. Mali should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) demonstrating timely access to accurate beneficial ownership information; (2) addressing pending technical compliance deficiencies with R.5 and 20, and identifying and investigating TF activities in line with the country's risk profile; and (3) implementing TFS related to TF and PF. The FATF notes Mali's continued progress across its action plan, however all deadlines have now expired and work remains. The FATF encourages Mali to continue to implement its action plan to address the above-mentioned strategic deficiencies as soon as possible.

Attached to Financial Follow-Up Unit Decision No. (2024/2) Regarding the lists of High-Risk Countries and Enhanced Monitoring Countries

Country	Core Areas
Monaco	In June 2024, Monaco made a high-level political commitment to work with the FATF and MONEYVAL to strengthen the effectiveness of its AML/CFT regime. Since the adoption of its mutual evaluation report (MER) in December 2022, Monaco has made significant progress on several of the MER's recommended actions including by establishing a new combined financial intelligence unit (FIU) and AML/CFT supervisor, strengthening its approach to detecting and investigating terrorism financing, implementing targeted financial sanctions and risk-based supervision of non-profit organisations. Monaco will continue to work with FATF to implement its action plan by: (1) strengthening the understanding of risk in relation to money laundering and income tax fraud committed abroad; (2) demonstrating a sustained increase in outbound requests to identify and seek the seizure of criminal assets abroad (3) enhancing the application of sanctions for AML/CFT breaches and breaches of basic and beneficial ownership requirements; (4) completing its resourcing program for its FIU and strengthen the quality and timeliness of STR reporting; (5) enhancing judicial efficiency, including through increasing resources of investigative judges and prosecutors and the application of effective, dissuasive and proportionate sanctions for money laundering; and (6) increasing the seizure of property suspected to derive from criminal activities.
Mozambique	Since October 2022, when Mozambique made a high-level political commitment to work with the FATF and ESAAMLG to strengthen the effectiveness of its AML/CFT regime, Mozambique has taken steps towards improving its AML/CFT regime, including by commencing the collection of beneficial ownership information, developing a CFT strategy and enhancing the capacity of CFT investigative and prosecutorial authorities, and addressing deficiencies in the TFS framework. Mozambique should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) providing adequate financial and human resources to supervisors, developing and implementing a risk-based supervision plan; (2) increasing the human resources of the FIU as well as increasing financial intelligence sent to authorities; (3) demonstrating LEAs' capability to effectively investigate a range of ML offences using financial intelligence; (4) conducting training for FIU, supervisors, and LEAs on the new legal and institutional framework for implementing TFS; and (6) carrying out the TF risk assessment for NPOs in line with the FATF Standards and using it as a basis to develop an outreach plan.
Namibia	(Statement from February 2024) <br> In February 2024, Namibia made a high-level political commitment to work with the FATF and ESAAMLG to strengthen the effectiveness of its AML/CFT regime.

Attached to Financial Follow-Up Unit Decision No. (2024/2) Regarding the lists of High-Risk Countries and Enhanced Monitoring Countries

Since the adoption of its MER in September 2022, Namibia has made progress on its MER's recommended actions to