Guidance to Financial Institutions on AML/CFT Risks Posed by Iran, Uzbekistan, Turkmenistan, Pakistan, and São Tomé and Príncipe

Advisory
FIN-2009-A007
Issued: October 28, 2009
Subject: Guidance to Financial Institutions Based on the Financial Action Task Force Statement on Anti-Money Laundering and Counter-Terrorist Financing Risks Posed by Iran, Uzbekistan, Turkmenistan, Pakistan, and São Tomé and Príncipe The Financial Crimes Enforcement Network (“FinCEN”) is issuing this advisory to inform banks and other financial institutions operating in the United States of the risks associated with deficiencies in the anti-money laundering (“AML”) and counter-terrorist financing (“CFT”) regimes of the following jurisdictions: Iran; Uzbekistan; Turkmenistan; Pakistan; and São Tomé and Príncipe. This advisory updates the FinCEN issuance of FIN-2009-A004,1 on July 10, 2009, regarding the same jurisdictions. On October 16, 2009, the Financial Action Task Force (“FATF”) issued a statement concerning these jurisdictions that explains its concerns regarding each jurisdiction and calls for action on the part of its members.2 The FATF statement is copied below and can be found on the FATF website.3 IRAN The FATF is concerned by Iran’s lack of engagement with the FATF and its failure to meaningfully address the ongoing and substantial deficiencies in its anti-money laundering and combating the financing of terrorism (AML/CFT) regime. The FATF remains particularly concerned about Iran’s failure to address the risk of terrorist financing and the serious threat this poses to the integrity of the international financial system. The FATF urges Iran to immediately and meaningfully address its