2025-03-11
Added · Updated
Licensees and registrants of the Securities Commission of The Bahamas are required to incorporate money laundering, terrorist financing, and proliferation financing risks associated with jurisdictions on the FATF's list of Jurisdictions under Increased Monitoring into their business relationship and transaction risk assessments. This obligation applies despite the FATF not calling for enhanced due diligence measures for these jurisdictions. The notice highlights the addition of Lao People’s Democratic Republic and Nepal to the list, the removal of the Philippines, and the deferral of reporting for several other countries, urging registrants to consider this updated information in their ongoing risk analyses.
Date: 7 March 2025 To: All Registrants and Licensees Re: Financial Action Task Force Public Statement on list of Jurisdictions under Increased Monitoring Licensees and registrants of the Securities Commission of The Bahamas (the Commission) are hereby informed that on 21 February 2025, the Financial Action Task Force (the FATF) issued a public statement regarding its list of Jurisdictions under Increased Monitoring. The FATF’s public statement provides updates on the status of Algeria, Angola, Bulgaria, Burkina Faso, Cameroon, Côte d’Ivoire, Croatia, Democratic Republic of Congo, Haiti, Kenya, Lebanon, Mali, Monaco, Mozambique, Namibia, Nigeria, Philippines (no longer subject to FATF increased monitoring), South Africa, South Sudan, Syria, Tanzania, Venezuela, Vietnam, Yemen and reflects the addition of Lao People’s Democratic Republic and Nepal to the FATF’s list of Jurisdictions under Increased Monitoring. Additionally, licensees and registrants are to note that the reporting for Algeria, Angola, Côte d’Ivoire, Haiti, Kenya, Lebanon, Monaco, Syria and Yemen were deferred, and therefore the statements issued previously by the FATF for these jurisdictions remain in effect but may not reflect the current status of the jurisdiction’s AML/CFT regime. In this regard, licensees and registrants are encouraged to take the ML/TF/PF risks associated with the jurisdictions identified in the FATF’s list of Jurisdictions under Increased Monitoring, into account in their risk assessments of business relationships and transactions, notwithstanding that the FATF does not call for the application of enhanced due diligence measures. A copy of the FATF’s October 2022, February 2023 and February 2025 public statements are attached hereto, and can be found at the following web addresses:
Home Publicaons Jurisdicons under Increased Monitoring - 21 February 2025 Jurisdicons under Increased Monitoring - 21 February 2025 Publicaon details Language English Country Algeria, Angola, Bulgaria, Burkina Faso, Cameroon, Côte d'Ivoire, Croaa, Democrac Republic of the Congo, Hai, Kenya, Lao PDR, Lebanon, Mali, Monaco, Mozambique, Namibia, Nepal, Nigeria, South Africa, South Sudan, Syria, Tanzania, Venezuela, Vietnam, Yemen NO LONGER SUBJECT TO FATF INCREASED Topic High-risk and other monitored jurisdicons English he ATF Countries Publicaons Topics Calendars
MONITORING Philippines "grey list" Paris, 21 February 2025 Jurisdicons under increased monitoring are acvely working with the FATF to address strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferaon financing. When the FATF places a jurisdicon under increased monitoring, it means the country has commied to resolve swily the idenfied strategic deficiencies within agreed meframes and is subject to
increased monitoring. This list is oen externally referred to as the “grey list”. The FATF and FATF-style regional bodies (FSRBs) connue to work with the jurisdicons below as they report on the progress achieved in addressing their strategic deficiencies. The FATF calls on these jurisdicons to complete their acon plans expediously and within the agreed meframes. The FATF welcomes their commitment and will closely monitor their progress. The FATF does not call for the applicaon of enhanced due diligence measures to be applied to these jurisdicons. The FATF Standards do not envisage de-risking, or cung-off enre classes of customers, but call for the applicaon of a risk-based approach. Therefore, the FATF encourages its members and all jurisdicons to take into account the informaon presented below in their risk analysis. As countries consider acons based on their risk analysis taking into account the informaon below, they should ensure that flows of funds for humanitarian assistance, legimate NPO acvity and remiances are neither disrupted nor discouraged. Countries should also consider their internaonal obligaons under United Naons Security Council Resoluon 2761 (2024) on humanitarian exempons to asset freeze measures imposed by UN sancons regimes. The FATF idenfies addional jurisdicons, on an on-going basis, that have strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferaon financing. A number of jurisdicons have not yet been reviewed by the FATF or their FSRBs, but will be in due course. The FATF provides some flexibility to jurisdicons not facing immediate deadlines to report progress on a voluntary basis. The following countries had their progress reviewed by the FATF since October 2024: Bulgaria; Burkina Faso, Cameroon, Croaa, Democrac Republic of Congo, Kenya, Mali, Mozambique, Namibia; Nigeria, Philippines, South Africa, South Sudan, Tanzania, Venezuela, and Vietnam. For these
countries, updated statements are provided below. Algeria, Angola, Côte d’Ivoire, Hai, Lebanon, Monaco, Syria and Yemen chose to defer reporng; thus, the statements issued previously for those jurisdicons are included below, but it may not necessarily reflect the most recent status of the jurisdicons’ AML/CFT regimes. Following review, the FATF now also idenfies Lao PDR and Nepal. (Statement from October 2024) In October 2024, Algeria made a high-level polical commitment to work with the FATF and MENAFATF to strengthen the effecveness of its AML/CFT regime. Since the adopon of its mutual evaluaon report (MER) in May 2023, Algeria has made progress on many of the MER’s recommended acons including by more effecvely pursuing money laundering invesgaons and prosecuons. Algeria will connue to work with FATF to implement its acon plan by: (1) improving risk-based supervision, especially for higher risk sectors, including through the adopon of new procedures, risk assessments, supervision manuals and guidelines, as well as undertaking inspecons and applying effecve, proporonate and dissuasive sancons; (2) developing an effecve framework for basic and beneficial ownership informaon; (3) enhancing its regime for suspicious transacon reports; (4) establishing an effecve legal and instuonal framework for targeted financial sancons for terrorism financing; and (5) implemenng a risk-based approach to oversight of non-profit organisaons, without disrupng or discouraging legimate acvity. (Statement from October 2024) In October 2024, Angola made a high-level polical commitment to work with the FATF and ESAAMLG to strengthen the effecveness of its AML/CFT regime. Since the adopon of its MER in June 2023, Angola has made progress on some of the ALGERIA ANGOLA
MER’s recommended acons including enhancing naonal cooperaon and coordinaon, internaonal cooperaon and the use of financial intelligence by competent authories. Angola will connue to work with the FATF to implement its FATF acon plan by: (1) enhancing its understanding of ML/TF risks; (2) improving risk-based supervision of non-financial banking enes and DNFBPs; (3) ensuring competent authories have adequate, accurate and mely access to beneficial ownership informaon and that breaches to obligaons are adequately addressed; (4) demonstrang an increase in ML invesgaons and prosecuons; (5) demonstrang the ability to idenfy, invesgate and prosecute TF; and (6) demonstrang an effecve process to implement targeted financial sancons without delay. Since October 2023, when Bulgaria made a high-level polical commitment to work with the FATF and MONEYVAL to strengthen the effecveness of its AML/CFT regime, Bulgaria has taken steps towards improving its AML/CFT regime, including by ensuring that the beneficial ownership informaon held in its Register is accurate and up-to-date and by idenfying the subset of non-profit organisaons (NPOs) most vulnerable to TF abuse. Bulgaria should connue to work on implemenng its acon plan to address its strategic deficiencies, including by: (1) addressing the remaining technical compliance deficiencies; (2) improving invesgaons and prosecuons of different types of money laundering in line with risks, including high-scale corrupon and organised crime; (3) ensuring the ability to conduct parallel financial invesgaons in all terrorism invesgaons; (4) addressing gaps in the PF TFS frameworks; and (5) demonstrang inial implementaon of risk-based monitoring of NPOs to prevent abuse for TF purposes. In February 2021, Burkina Faso made a high-level polical commitment to work with the FATF and GIABA to strengthen the effecveness of its AML/CFT regime, Burkina Faso should connue to work on implemenng its acon plan to address BULGARIA BURKINA FASO
its remaining strategic deficiency, by implemenng an effecve targeted financial sancons regime related to TF and PF. The FATF notes Burkina Faso’s connued progress across its acon plan, however all deadlines have expired and work remains. The FATF urges Burkina Faso to swily implement its acon plan to address the above-menoned strategic deficiency as soon as possible as all deadlines expired in December 2022. In June 2023, Cameroon made a high-level polical commitment to work with the FATF and GABAC to strengthen the effecveness of its AML/CFT regime. Cameroon has taken steps to improve its AML/CFT regime by aligning AML/CFT naonal strategies and policies with the findings of the NRA; demonstrang AML/CFT cooperaon and coordinaon between competent authories; improving risk-based priorisaon of incoming internaonal cooperaon, and establishing a regime for violaons of transparency obligaons applicable to legal persons. Cameroon should connue working on implemenng its acon plan to address its strategic deficiencies, including by: (1) enhancing risk-based supervision of banks and implemenng effecve risk-based supervision for nonbank FIs and DNFBPs, and conducng appropriate outreach to high-risk FIs and DNFBPs; (2) maintaining and ensuring mely access by competent authories to adequate and up to date beneficial ownership informaon on legal persons; (3) enhancing secure informaon exchange between the FIU, reporng enes and competent authories and demonstrang an increase in disseminaon of intelligence reports to support operaonal needs of competent authories; (4) demonstrang that authories are able to conduct a range of ML invesgaons, and prosecute ML in line with risks; (5) implemenng policies and procedures for seizing and confiscang proceeds and instrumentalies of crime and managing frozen, seized and confiscated property, and priorising seizure and confiscaon of assets at the border; (6) demonstrang that TF invesgaons and prosecuons are pursued in line with risk; and (7) demonstrang effecve implementaon of TF and PF TFS regimes and implemenng a risk-based approach to NPOs without disrupng legimate NPO acvies. CAMEROON CÔTE D'IVOIRE
(Statement from October 2024) In October 2024, Côte d’Ivoire made a high-level polical commitment to work with the FATF and GIABA to strengthen the effecveness of its AML/CFT regime. Since the adopon of its MER in June 2023, Côte d’Ivoire has made significant progress on many of the MER’s recommended acons including by strengthening its legal AML/CFT framework through several important legislave and regulatory amendments, updang ML/TF analysis by draing typology reports on the highest risk predicate offences, strengthening the human and technical resources of the FIU and prosecutors, and operaonalising the agency in charge of the management of assets seized and confiscated. Côte d’Ivoire will connue to work with the FATF to implement its FATF acon plan by: (1) enhancing its use of internaonal cooperaon in ML/TF invesgaons and prosecuons; (2) improving the implementaon of risk-based supervision of financial instuons and designated non-financial businesses and professions and conducng outreach campaigns to improve compliance; (3) improving the verificaon and access of basic and beneficial ownership informaon of legal persons and applying sancons in case of violaon; (4) enhancing the use of financial intelligence by law enforcement authories and improving disseminaons by the FIU; (5) demonstrang a sustained increase in the number of ML and TF invesgaons and prosecuons of different types in line with the country’s risk profile; and (6) strengthening the targeted financial sancons framework. In June 2023, Croaa made a high-level polical commitment to work with the FATF and MONEYVAL to strengthen the effecveness of its AML/CFT regime. At its February 2025 Plenary, the FATF made the inial determinaon that Croaa has substanally completed its acon plan and warrants an on-site assessment to verify that the implementaon of AML/CFT reforms has begun and is being sustained, and that the necessary polical commitment remains in place to sustain implementaon in the future. Croaa has made the following key reforms including: (1) compleng the naonal risk assessment, including assessing the ML/TF risk associated with the misuse of CROATIA
legal persons and legal arrangements and the use of cash in the real estate sector; (2) increasing FIU human resources and improving analycal capabilies; (3) connuing to improve LEA detecon, invesgaon and prosecuon of different types of ML, including ML involving foreign predicate offences and the misuse of legal persons; (4) demonstrang a sustained increase in the applicaon of provisional measures in securing direct/indirect proceeds, as well as foreign proceeds subject to confiscaon; (5) demonstrang the ability to systemacally detect and where relevant invesgate TF in line with its risk profile; (6) establishing a naonal framework for the implementaon of UN TFS measures and providing guidance and conducng outreach and training to reporng enes; and (7) idenfying the subset of NPOs most vulnerable to TF abuse and providing targeted outreach to NPOs and to the donor community on potenal vulnerabilies of NPOs to TF abuse. Since October 2022, when the DRC made a high-level polical commitment to work with the FATF and GABAC to strengthen the effecveness of its AML/CFT regime, the DRC has taken steps towards improving its AML/CFT regime, including by establishing a mechanism to promote interagency coordinaon and cooperaon on both ML and TF at the operaonal level. The DRC should connue to work to implement its FATF acon plan to address its strategic deficiencies, including by: (1) developing and implemenng a risk-based supervision plan; (2) building the capacity of the FIU to conduct operaonal and strategic analysis; (3) strengthening the capabilies of authories involved in the invesgaon and prosecuon of ML and TF; and (4) demonstrang effecve implementaon of TF and PF-related TFS. (Statement from June 2024) Since June 2021, when Hai made a high-level polical commitment to work with the FATF and CFATF to strengthen the effecveness of its AML/CFT regime, Hai DEMOCRATIC REPUBLIC OF THE CONGO HAITI
has taken steps towards improving its AML/CFT regime, including improving the FIU’s access to and use of a wide range of informaon in its financial intelligence products through the adopon of a new organic law. The FATF recognises the polical commitment expressed at a high level and the efforts demonstrated by Hai to advance its commitments in the midst of the challenging social, economic and security situaon within the country. Hai should connue to work on implemenng its acon plan to address its strategic deficiencies, including by: (1) compleng its ML/TF risk assessment process and disseminang the findings; (2) implemenng risk-based AML/CFT supervision for all financial instuons and DNFBPs deemed to constute a higher ML/TF risk; (3) ensuring basic and beneficial ownership informaon are maintained and accessible in a mely manner; (4) ensuring the FIU has adequate resources and processes to produce and disseminate operaonal and strategic analysis to competent authories for combang ML and TF; (4) demonstrang authories are idenfying, invesgang and prosecung ML cases in a manner consistent with Hai’s risk profile; (5) demonstrang an increase of idenficaon, tracing and recovery of proceeds of crimes; (6) addressing the technical deficiencies in its targeted financial sancons regime; and (7) conducng appropriate risk-based monitoring of NPOs vulnerable to TF abuse without disrupng or discouraging legimate NPO acvies. The FATF notes Hai’s connued progress across its acon plan, however all deadlines are expired and work remains. The FATF encourages Hai to connue to implement its acon plan to address the above-menoned strategic deficiencies. Since February 2024, when Kenya made a high-level polical commitment to work with the FATF and ESAAMLG to strengthen the effecveness of its AML/CFT regime, Kenya has taken steps towards improving its AML/CFT regime, including by compleng a TF risk assessment and by bringing its TFS framework related to proliferaon financing into compliance. Kenya should connue to work to implement its FATF acon plan to address its strategic deficiencies, including by: (1) presenng the results of the NRA and other risk assessments in a consistent manner to competent authories and the private sector and updang the naonal AML/CFT strategies; (2) improving risk-based AML/CFT supervision of FIs and DNFBPs and adopng a legal framework for the licensing and supervision of KENYA
VASPs; (3) enhancing the understanding of prevenve measures by FIs and DNFBPs, including to increase STR filing and implement TFS without delay; (4) designang an authority for the regulaon of trusts and collecon of accurate and up-to-date beneficial ownership informaon and implemenng remedial acons 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 invesgaons and prosecuons in line with risks; (7) bringing the TFS framework in compliance with R.6 and ensure its effecve implementaon; and (8) revising the framework for NPO regulaon and oversight to ensure that migang measures are risk-based and do not disrupt or discourage legimate NPO acvity. In February 2025, Lao PDR made a high-level polical commitment to work with the FATF and APG to strengthen the effecveness of its AML/CFT regime. Since the adopon of its MER in August 2023, Lao PDR has made progress on some of the MER’s recommended acons including increasing FIU resources and eliminang bearer shares. Lao PDR will connue to work with the FATF to implement its FATF acon plan by: (1) enhancing its understanding of ML/TF risks; (2) improving risk-based supervision of casinos, banks and reporng enes in SEZs, including fit and proper checks; (3) enhancing the quality and quanty of financial intelligence analysis and spontaneous disseminaon to law enforcement agencies; (4) ensuring law enforcement agencies receive training and guidance on money laundering; (5) demonstrang an increase in ML invesgaons and prosecuons in line with Lao PDR’s risk profile, with an emphasis on crimes with a transnaonal element that require internaonal cooperaon; (6) developing a naonal confiscaon policy consistent with its ML/TF risks; (7) demonstrang that relevant competent authories are taking measures to idenfy, seize and, where applicable, confiscate proceeds and instrumentalies of crime in line with the risk profile; (8) monitoring FIs’ and DNFBPs’ compliance with TFS PF obligaons; and (9) addressing technical compliance deficiencies in Recommendaons 5, 6, 7 and 10. LAO PDR LEBANON
(Statement from October 2024) In October 2024, Lebanon made a high-level polical commitment to work with the FATF and MENAFATF to strengthen the effecveness of its AML/CFT regime in spite of the challenging social, economic and security situaon within the country. Since the adopon of its MER in May 2023, Lebanon has made progress on several of the MER’s recommended acons and has applied measures to its financial sector, including through issuing a circular for banks and financial instuons to establish a department dedicated to combang bribery and corrupon related crimes and guidance on polically exposed persons, while taking measures against unlicensed financial acvity. Lebanon will connue to work with the FATF to implement its FATF acon plan by: (1) conducng assessments of specific terrorist financing and money laundering risks idenfied in the MER and ensuring that policies and measures are in place to migate these risks; (2) enhancing mechanisms to ensure the mely and effecve execuon of requests for mutual legal assistance, extradion and asset recovery; (3) enhancing DNFBPs’ risk understanding and applying effecve, proporonate and dissuasive sancons for breaches of AML/CFT obligaons; (4) ensuring beneficial ownership informaon is up-to-date and that there are adequate sancons and risk-migang in place for legal persons; (5) enhancing competent authories’ use of products of the FIU and financial intelligence; (6) demonstrang a sustained increase in invesgaons, prosecuons and court rulings for types of ML in line with the risk; (7) improving its approach to asset recovery and idenfying and seizing illicit cross-border movements of currency and precious metals and stones; (8) pursuing TF invesgaons and sharing informaon with foreign partners related to invesgaons of TF as called for in the MER; (9) enhancing the implementaon of targeted financial sancons without delay, parcularly at DNFBPs and certain non-banking financial instuons; and (10) undertaking targeted and risk-based monitoring of high-risk NPOs, without disrupng or discouraging legimate NPO acvies. MALI
In October 2021, Mali made a high-level polical commitment to work with the FATF and GIABA to strengthen the effecveness of its AML/CFT regime. At its February 2025 plenary, the FATF made the inial determinaon that Mali has substanally completed its acon plan and warrants an on-site assessment to verify that the implementaon of AML/CFT reforms has begun and is being sustained, and that the necessary polical commitment remains in place to sustain implementaon in the future. Mali has made key reforms by: (1) disseminang the results of the NRA to all relevant stakeholders including by conducng awareness raising acvies with the highest risk sectors; (2) developing a risk based approach for the AML/CFT supervision of all FIs and higher risk DNFBPs and demonstrang effecve, proporonate and dissuasive sancons for noncompliance; (3) conducng a comprehensive assessment of ML/TF risks associated with all types of legal persons; (4) increasing the capacity of the FIU and the LEAs and enhancing their cooperaon on the use of financial intelligence; (5) ensuring relevant competent authories are involved in invesgaon and prosecuon of ML; (6) strengthening the capacies of relevant authories responsible for invesgaon and prosecuon of TF cases; (7) establishing a legal framework and procedures to implement targeted financial sancons; and (8) implemenng a risk-based approach for supervision of the NPO sector to prevent abuse for TF purposes. (Statement from June 2024) In June 2024, Monaco made a high-level polical commitment to work with the FATF and MONEYVAL to strengthen the effecveness of its AML/CFT regime. Since the adopon of its mutual evaluaon report (MER) in December 2022, Monaco has made significant progress on several of the MER’s recommended acons including by establishing a new combined financial intelligence unit (FIU) and AML/CFT supervisor, strengthening its approach to detecng and invesgang terrorism financing, implemenng targeted financial sancons and risk-based supervision of non-profit organisaons. Monaco will connue to work with FATF to implement its acon plan by: (1) strengthening the understanding of risk in MONACO
relaon to money laundering and income tax fraud commied abroad; (2) demonstrang a sustained increase in outbound requests to idenfy and seek the seizure of criminal assets abroad (3) enhancing the applicaon of sancons for AML/CFT breaches and breaches of basic and beneficial ownership requirements; (4) compleng its resourcing program for its FIU and strengthen the quality and meliness of STR reporng; (5) enhancing judicial efficiency, including through increasing resources of invesgave judges and prosecutors and the applicaon of effecve, dissuasive and proporonate sancons for money laundering; and (6) increasing the seizure of property suspected to derive from criminal acvies. Since October 2022, when Mozambique made a high-level polical commitment to work with the FATF and ESAAMLG to strengthen the effecveness of its AML/CFT regime, Mozambique has taken steps towards improving its AML/CFT regime, including by implemenng a risk-based supervision plan along with effecve and proporonate sancons, increasing financial intelligence sent to authories and demonstrang the ability to idenfy TF cases. Mozambique should connue to work on implemenng its acon plan to address its strategic deficiencies, including by: (1) carrying out a risk assessment for NPOs in line with the FATF Standards and using it as a basis to develop an outreach plan. Since February 2024, when Namibia made a high-level polical commitment to work with the FATF and ESAAMLG to strengthen the effecveness of its AML/CFT regime, Namibia has taken steps towards improving its AML/CFT regime, including by strengthening FIU resources dedicated to both its supervision responsibilies and operaonal and strategic analysis, and increasing the LEAs’ financial and human resources dedicated to TF. Namibia should connue working on implemenng its FATF acon plan to address strategic deficiencies, including by: (1) strengthening its AML/CFT risk based supervision through conducng offsite and onsite inspecons informed by supervisory risk assessment tools and applying effecve, proporonate and dissuasive sancons for breaches of MOZAMBIQUE NAMIBIA
AML/CFT obligaons; (2) enhancing prevenve measures through inspecons and outreach to ensure that FIs and DNFBPs apply enhanced due diligence measures as well as TFS obligaons related to TF and PF without delay; (3) increasing the filing of beneficial ownership informaon of legal persons and arrangements, and applying remedial acons and/or effecve, proporonate and dissuasive sancons against breaches of compliance with beneficial ownership obligaons; (4) improving the cooperaon between the FIU and LEAs to enhance the use and integraon of financial intelligence in invesgaons; (5) enhancing the operaonal capabilies of authories involved in ML invesgaons and prosecuons by providing them with adequate resources and targeted trainings; (6) demonstrang the LEAs’ capabilies to effecvely invesgate and prosecute ML/TF cases. In February 2025, Nepal made a high-level polical commitment to work with the FATF and APG to strengthen the effecveness of its AML/CFT regime. Since the adopon of its MER in August 2023, Nepal has made progress on some of the MER’s recommended acons including streamlining MLA requests and increasing the capabilies of the FIU. Nepal will connue to work with the FATF to implement its FATF acon plan by: (1) improving its understanding of key ML/TF risks; (2) improving risk-based supervision of commercial banks, higher risk cooperaves, casinos, DPMS and real estate sector; (3) demonstrang idenficaon and sanconing of materially significant illegal MVTS/hundi providers, without hindering financial inclusion; (4) increasing capacity and coordinaon of competent authories to conduct ML invesgaons; (5) demonstrang an increase in ML invesgaons and prosecuons; (6) demonstrang measures to idenfy, trace, restrain, seize and, where applicable, confiscate proceeds and instrumentalies of crime in line with the risk profile; (7) addressing technical compliance deficiencies in its targeted financial sancons regime for TF and PF. NEPAL NIGERIA
Since February 2023, when Nigeria made a high-level polical commitment to work with the FATF and GIABA to strengthen the effecveness of its AML/CFT regime, Nigeria has taken steps towards improving its AML/CFT regime, including by improving AML/CFT risk-based supervision of FIs and DNFBPs, ensuring that competent authories have mely access to accurate and up-to-date beneficial ownership informaon on legal persons and demonstrang a sustained increase in ML and TF invesgaons and prosecuons in line with the country’s risk profile.. Nigeria should connue to work on implemenng its acon plan to address its strategic deficiencies, including by: (1) enhancing implementaon of prevenve measures for high-risk sectors; and (2) proacvely detecng violaons of currency declaraon obligaons and applying appropriate sancons. Since February 2023, when South Africa made a high-level polical commitment to work with the FATF and ESAAMLG to strengthen the effecveness of its AML/CFT regime, South Africa has taken steps towards improving its AML/CFT regime including by demonstrang that all supervisors apply effecve, proporonate, and effecve sancons, ensuring competent authories have mely access to accurate and up to date BO informaon on legal persons and arrangements and applying sancons for breaches of violaon by legal persons to beneficial ownership obligaons. South Africa should connue to work on implemenng its acon plan to address its remaining strategic deficiency on demonstrang a sustained increase in invesgaons and prosecuons of serious and complex money laundering and the full range of TF acvies in line with its risk profile. Since June 2021, when South Sudan made a high-level polical commitment to work with the FATF and ESAAMLG to strengthen the effecveness of its AML/CFT SOUTH AFRICA SOUTH SUDAN
regime, South Sudan has taken steps towards improving its AML/CFT regime, including by finalising its comprehensive review of the AML/CFT Act (2012) to comply with the FATF Standards. South Sudan should connue to work to implement its acon plan, including by: ; (1) fully implemenng the 1988 Vienna Convenon, the 2000 Palermo Convenon, and the 1999 Terrorist Financing Convenon; (2) ensuring that competent authories are suitably structured and capacitated to implement a risk-based approach to AML/CFT supervision for financial instuons; (3) developing a comprehensive legal framework to collect and verify the accuracy of beneficial ownership informaon for legal persons; (4) finalising the operaonalisaon of a fully funconing and independent FIU; (5) establishing and implemenng the legal and instuonal framework to implement targeted financial sancons in compliance with United Naons Security Council Resoluons on terrorism and WMD proliferaon financing; and (6) commencing implementaon of targeted risk-based supervision/monitoring of NPOs at risk of TF abuse. The FATF notes South Sudan’s limited progress across its acon plan with all deadlines now expired and work remaining. The FATF again encourages South Sudan to connue to implement its acon plan to address the above-menoned strategic deficiencies as soon as possible and demonstrate strong polical and instuonal commitment to strengthen the effecveness of its AML/CFT regime, parcularly in supporng the lead AML/CFT agency in coordinang naonal AML/CFT efforts. (Statement from February 2023) Since February 2010, when Syria made a high-level polical commitment to work with the FATF and MENAFATF to address its strategic AML/CFT deficiencies, Syria has made progress to improve its AML/CFT regime. In June 2014, the FATF determined that Syria had substanally addressed its acon plan at a technical level, including by criminalising terrorist financing and establishing procedures for freezing terrorist assets. While the FATF determined that Syria has completed its agreed acon plan, due to the security situaon, the FATF has been unable to conduct an on-site visit to confirm whether the process of implemenng the required reforms and acons has begun and is being sustained. The FATF will SYRIA
connue to monitor the situaon, and will conduct an on-site visit at the earliest possible date. In October 2022, Tanzania made a high-level polical commitment to work with the FATF and ESAAMLG to strengthen the effecveness of its AML/CFT regime. At its February 2025 plenary, the FATF made the inial determinaon that Tanzania has substanally completed its acon plan and warrants an on-site assessment to verify that the implementaon of AML/CFT reforms has begun and is being sustained, and that the necessary polical commitment remains in place to sustain implementaon in the future. Tanzania has made the following key reforms: (1) improving risk-based supervision of FIs and DNFBPs, including by conducng inspecons on a risksensive basis and applying effecve, proporonate, and dissuasive sancons for non-compliance; (2) demonstrang authories’ capability to effecvely conduct a range of invesgaons and prosecuons of ML in line with the country’s risk profile; (3) demonstrang that LEAs are taking measures to idenfy, trace, seize, and confiscate proceeds and instrumentalies of crime; (4) conducng a comprehensive TF Risk Assessment and begin implemenng a comprehensive naonal CFT strategy as well as demonstrang capability to conduct TF invesgaons and pursue prosecuons in line with the country’s risk profile; (5) increasing awareness of the private sector and competent authories on TF and PF-related 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. In June 2024, Venezuela made a high-level polical commitment to work with the FATF and CFATF to strengthen the effecveness of its AML/CFT regime. Venezuela should connue working on implemenng its FATF acon plan to address its strategic deficiencies by: (1) strengthening its understanding of ML/TF risks, including in relaon to TF and legal persons and arrangements; (2) ensuring the TANZANIA VENEZUELA
full range of financial instuons and DNFBPs are subject to AML/CFT measures and risk-based supervision; (3) ensuring adequate, accurate and up-to-date beneficial ownership informaon is accessible in a mely manner; (4) enhancing the resources of the FIU and improving competent authories’ use of financial intelligence; (5) enhancing the invesgaon and prosecuon of ML and TF; (6) ensuring measures to prevent the abuse of NPOs for TF are targeted, proporonate, and risk-based and do not disrupt or discourage legimate acvies within the NPO sector; and (7) implemenng TF-and PF-related targeted financial sancons without delay Since June 2023, when Vietnam made a high-level polical commitment to work with the FATF and APG to strengthen the effecveness of its AML/CFT regime, Vietnam has made limited progress. The FATF strongly encourages Vietnam to coordinate internally to demonstrate progress on its acon plan to address its strategic deficiencies, including by: (1) increasing risk understanding, domesc coordinaon and co-operaon to combat ML/TF; (2) enhancing internaonal cooperaon; (3) implemenng effecve risk-based supervision for FIs and DNFBPs; (4) taking acon to regulate virtual assets and virtual asset service providers; (5) addressing technical compliance deficiencies, including with respect to the ML offence, targeted financial sancons, customer due diligence and suspicious transacon reporng; (6) conducing outreach acvies with the private sector; (7) establishing a regime that provides competent authories with adequate, accurate and up-to-date informaon on beneficial ownership; (8) ensuring the independence of the FIU and enhancing the quality and quanty of financial intelligence analysis and disseminaons; (9) priorizing parallel financial invesgaons and demonstrang an increase in the number of ML invesgaons and prosecuons undertaken; and (10) demonstrang that there is monitoring of FIs and DNFBPs for compliance with PF TFS obligaons and that there is cooperaon and co-ordinaon between authories to prevent PF TFS from being evaded. VIETNAM YEMEN
(Statement from February 2023) Since February 2010, when Yemen made a high-level polical commitment to work with the FATF and MENAFATF to address its strategic AML/CFT deficiencies, Yemen has made progress to improve its AML/CFT regime. In June 2014, the FATF determined that Yemen had substanally addressed its acon plan at a technical level, including by: (1) adequately criminalising money laundering and terrorist financing; (2) establishing procedures to idenfy and freeze terrorist assets; (3) improving its customer due diligence and suspicious transacon reporng requirements; (4) issuing guidance; (5) developing the monitoring and supervisory capacity of the financial sector supervisory authories and the financial intelligence unit; and (6) establishing a fully operaonal and effecvely funconing financial intelligence unit. While the FATF determined that Yemen has completed its agreed acon plan, due to the security situaon, the FATF has been unable to conduct an on-site visit to confirm whether the process of implemenng the required reforms and acons has begun and is being sustained. The FATF will connue to monitor the situaon, and conduct an on-site visit at the earliest possible date. The FATF welcomes the Philippines’ significant progress in improving its AML/CFT regime. The Philippines strengthened the effecveness of its AML/CFT regime to meet the commitments in its acon plan regarding the strategic deficiencies that the FATF idenfied in June 2021 by (1) demonstrang that effecve risk-based supervision of DNFBPs is occurring; (2) demonstrang that supervisors are using AML/CFT controls to migate risks associated with casino junkets; (3) JURISDICTION NO LONGER SUBJECT TO INCREASED MONITORING BY THE FATF PHILIPPINES
implemenng the new registraon requirements for MVTS and applying sancons to unregistered and illegal remiance operators; (4) enhancing and streamlining LEA access to BO informaon and taking steps to ensure that BO informaon is accurate and up-to-date; (5) demonstrang an increase in the use of financial intelligence and an increase in ML invesgaons and prosecuons in line with risk; (6) demonstrang an increase in the idenficaon, invesgaon and prosecuon of TF cases; (7) demonstrang that appropriate measures are taken with respect to the NPO sector (including unregistered NPOs) without disrupng legimate NPO acvity; (8) enhancing the effecveness of the targeted financial sancons framework for both TF and PF; and (9) applying cross-border measures in all main internaonal sea/airports, in line with the risk. The Philippines should connue to work with APG to sustain its improvements in its AML/CFT system. The FATF encourages the Philippines to connue its work in ensuring that its CFT measures are appropriately applied, parcularly the idenficaon and prosecuon of TF cases, and are neither discouraging nor disrupng legimate NPO acvity. Related materials 21 Feb 2025 The second Financial Acon Task Force (FATF) Plenary under the two-year Mexico Presidency of Elisa de Anda Madrazo concluded today. Delegates discussed key issues including the promoon of financial inclusion and the risk-based approach, a key priority of the FATF under its Mexican Presidency. 21 Feb 2025 Outcomes FATF Plenary, 19-21 February 2025 High-Risk Jurisdicons subject to a Call for Acon - 21 February 2025
Discover Need help? High-risk jurisdicons have significant strategic deficiencies in their regimes to counter money laundering, terrorist financing, and financing of proliferaon. For all countries idenfied as highrisk, the FATF calls on all members and urges all jurisdicons to apply enhanced due diligence, and, in the most serious cases, countries are called upon to apply countermeasures to protect the internaonal financial system from the money laundering, terrorist financing, and proliferaon financing (ML/TF/PF) risks emanang from the country. The FATF ↙ Countries ↙ Publicaons ↙ Calendars ↙ Private Sector ↙ Informaon for students and academia ↙ Fraud Warning ↙ Frequently Asked Quesons ↙
Home Publications Jurisdictions under Increased Monitoring - 24 February 2023 Jurisdictions under Increased Monitoring - 24 February 2023 Publication details Language English Country Albania | Barbados | Burkina Faso | Cambodia | Cayman Islands | Democratic Republic of the Congo | Gibraltar | Haiti | Jamaica | Jordan | Mali | Morocco | Mozambique | Nigeria | Panama | Philippines | Senegal | South Africa|South Sudan |Syria | Tanzania | Türkiye | Uganda | United Arab Emirates | Yemen Topic High-risk and other monitored jurisdictions The FATF Countries Publications Topics Calendars
Jurisdictions No Longer Subject to Increased Monitoring by the FATF • Albania • Barbados • Burkina Faso • The Cayman Islands • The Democratic Republic of the Congo • Gibraltar • Haiti • Jamaica • Jordan • Mali • Mozambique • Nigeria • Panama • Philippines • Senegal • South Africa • South Sudan • Syria • Tanzania • Türkiye • Uganda • United Arab Emirates • Yemen
Outcomes FATF Plenary, 22-24 February 2023 High-Risk Jurisdictions subject to a Call for Action – 24 February 2023 Paris, 24 February 2023 - Jurisdictions under increased monitoring are actively working with the FATF to address strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing. When the FATF places a jurisdiction under increased monitoring, it means the country has committed to resolve swiftly the identified strategic deficiencies within agreed timeframes and is subject to increased monitoring. This list is often externally referred to as the “grey list”. The FATF and FATF-style regional bodies (FSRBs) continue to work with the jurisdictions below as they report on the progress achieved in addressing their strategic deficiencies. The FATF calls on these jurisdictions to complete their action plans expeditiously and within the agreed timeframes. The FATF welcomes their commitment and will closely monitor their progress. The FATF does not call for the application of enhanced due diligence measures to be applied to these jurisdictions. The FATF Standards do not envisage de-risking, or cutting-off entire classes of customers, but call for the application of a riskbased approach. Therefore, the FATF encourages its members and all jurisdictions to take into account the information presented below in their risk analysis. The FATF identifies additional jurisdictions, on an on-going basis, that have strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing. A number of jurisdictions have not yet been reviewed by the FATF or their FSRBs, but will be in due course. Since the start of the COVID-19 pandemic, the FATF has provided some flexibility to jurisdictions not facing immediate deadlines to report progress on a voluntary basis. The following countries had their progress reviewed by the FATF • Cambodia • Morocco
since October 2022: Albania, Barbados, Burkina Faso, Cambodia, Cayman Islands, Gibraltar, Haiti, Jamaica, Jordan, Mali, Morocco, Myanmar, Panama, Philippines, Senegal, South Sudan, Türkiye, UAE, and Uganda. For these countries, updated statements are provided below. The Democratic Republic of the Congo, Mozambique, and Tanzania chose to defer reporting; thus, the statements issued in October 2022 for those jurisdictions are included below, but it may not necessarily reflect the most recent status of the jurisdictions’ AML/CFT regimes. Following review, the FATF now also identifies Nigeria and South Africa. Since February 2020, when Albania made a high-level political commitment to work with the FATF and MONEYVAL to strengthen the effectiveness of its AML/CFT regime, Albania has taken steps towards improving its AML/CFT regime, including by demonstrating a meaningful increase in the number of money laundering cases indicted, particularly those stemming from foreign offences where the criminal proceeds were laundered in Albania. The FATF has made the initial determination that Albania has substantially completed its action plan and appreciates Albania’s work to address its strategic deficiencies. However, the FATF has not yet decided to authorise an on-site visit to the country to verify the implementation of Albania’s AML/CFT reforms. This is because the FATF remains concerned that Albania’s apparent plans to establish a Voluntary Tax Compliance (VTC) programme do not comply with the FATF’s principles for managing the AML/CFT implications of VTC programmes or FATF’s best practices in this area. Albania should ensure that any amnesty provisions included in the VTC law do not present an opportunity for individuals or legal persons to legalise or repatriate assets of unlawful origin and that any criminal amnesty only relates to the previous incorrect or non-reporting of taxable income. Albania should revise its draft VTC law and work with MONEYVAL to ensure that any VTC law passed or implemented has adequate safeguards to prevent the potential for abuse of the programme for money laundering ALBANIA
purposes. Alternatively, it could consider abandoning the planned VTC programme altogether. Since February 2020, when Barbados made a high-level political commitment to work with the FATF and CFATF to strengthen the effectiveness of its AML/CFT regime, Barbados has taken steps towards improving its AML/CFT regime, including by, taking appropriate measures to prevent legal persons and arrangements from being misused for criminal purposes, and by demonstrating that ML investigations and prosecutions are in line with the country’s risk profile. Barbados should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) ensuring that accurate and up-to-date beneficial ownership information is available on a timely basis; (2) further pursuing repatriation or sharing of confiscated assets with other countries. The FATF expresses concern that Barbados failed to complete its action plan, which fully expired in April 2022. The FATF strongly urges Barbados to swiftly demonstrate significant progress in completing its action plan by June 2023 or the FATF will consider next steps if there is insufficient progress. 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 increasing ML investigations and the use of international cooperation in line with its risk profile. Burkina Faso should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) updating its understanding of ML/TF BARBADOS BURKINA FASO
risks, including through the revision of the national risk assessment in line with the sectoral priorities identified in its national strategy; (2) strengthening of resource capacities of all AML/CFT supervisory authorities and implementing risk based supervision of FIs and DNFBPs; (3) maintaining comprehensive and updated basic and beneficial ownership information of legal persons and strengthening the system of sanctions for violations of transparency obligations; (4) increasing the diversity of suspicious transactions reporting; (5) establishing procedures for effective implementation of declaration of cross-border declaration of currencies and bearer negotiable instruments; (6) enhancing cooperation between LEAs and prosecutorial authorities combatting TF and conducting TF investigations and prosecutions in line with its risk profile; and (7) implementing an effective targeted financial sanctions regime related to TF and PF as well as risk-based monitoring and supervision of NPOs. The FATF notes Burkina Faso’s continued progress across its action plan, however all deadlines have now expired and work remains. The FATF encourages Burkina Faso to continue to implement its action plan to address the above-mentioned strategic deficiencies as soon as possible. Since February 2021, when the Cayman Islands made a high-level political commitment to work with the FATF and CFATF to strengthen the effectiveness of its AML/CFT regime, the Cayman Islands has taken steps towards improving its AML/CFT regime, including by advancing ML prosecutions into convictions and demonstrating progress on complex ML cases with a foreign predicate. However, the Cayman Islands should continue to work on implementing its action plan to address its remaining strategic deficiencies, by demonstrating that they are prosecuting all types of money laundering cases in line with the jurisdiction’s risk profile and that such prosecutions are resulting in the application of dissuasive, effective, and proportionate sanctions. THE CAYMAN ISLANDS
The FATF expresses concern that the Cayman Islands failed to complete its action plan, which fully expired in May 2022. The FATF strongly urges the Cayman Islands to swiftly demonstrate significant progress in completing its action plan by June 2023 or the FATF will consider next steps if there is insufficient progress. (Statement from October 2022) In October 2022, the DRC made a high-level political commitment to work with the FATF and GABAC to strengthen the effectiveness of its AML/CFT regime. Since the adoption of its MER in October 2020, the DRC has made progress on some of the MER’s recommended actions including making confiscation of proceeds of crime a policy priority. The DRC will work to implement its FATF action plan by: (1) finalising the NRA on ML and TF and adopting an AML/CFT national strategy; (2) designating supervisory authorities for all DNFBP sectors, and developing and implementing a riskbased supervision plan; (3) adequately resourcing the FIU, and build its capacity to conduct operational and strategic analysis; (4) strengthening the capabilities of authorities involved in the investigation and prosecution of ML and TF; and (5) demonstrating effective implementation of TF and PFrelated TFS. Since June 2022, when Gibraltar made a high-level political commitment to work with the FATF and MONEYVAL to strengthen the effectiveness of its AML/CFT regime, Gibraltar has taken steps to do so, including by demonstrating that the supervisors for trust and company service providers, lawyers, gaming businesses, real estate agents, and other nonbank entities are now using a range of effective, proportionate, and THE DEMOCRATIC REPUBLIC OF THE CONGO GIBRALTAR
dissuasive sanctions for AML/CFT breaches, specifically by taking more enforcement actions, imposing financial penalties, and publishing the results of cases, where appropriate. Gibraltar should continue to work on implementing its action plan to address its strategic deficiencies, including by showing that it is able to pursue more final confiscation judgments commensurate with the risk and context of Gibraltar. In June 2021, Haiti made a high-level political commitment to work with the FATF and CFATF to strengthen the effectiveness of its AML/CFT regime. 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) facilitating information sharing with relevant foreign counterparts; (3) addressing the technical deficiencies in its legal and regulatory framework that impede the implementation of AML/CFT preventive measures and implementing riskbased AML/CFT supervision for all financial institutions and DNFBPs deemed to constitute a higher ML/TF risk; (4) ensuring basic and beneficial ownership information are maintained and accessible in a timely manner; (5) ensuring a better use of financial intelligence and other relevant information by competent authorities for combatting ML and TF; (6) addressing the technical deficiencies in its ML offence and demonstrating authorities are identifying, investigating and prosecuting ML cases in a manner consistent with Haiti’s risk profile; (7) demonstrating an increase of identification, tracing and recovery of proceeds of crimes; (8) addressing the technical deficiencies in its TF offence and targeted financial sanctions regime; and (9) conducting appropriate risk-based monitoring of NPOs vulnerable to TF abuse without disrupting or discouraging legitimate NPO activities. HAITI
Since February 2020, when Jamaica made a high-level political commitment to work with the FATF and CFATF to strengthen the effectiveness of its AML/CFT regime, Jamaica has taken steps towards improving its AML/CFT regime, including by introducing its Charities regulations and bringing the microcredit sector under AML/CFT supervision. Jamaica should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) including all DNFBPs in the AML/CFT regime and ensuring adequate, risk-based supervision in all sectors; and (2) ensuring that BO definition is in line with the FATF Standards, taking appropriate measures to prevent legal persons and arrangements from being misused for criminal purposes, and ensuring that accurate and up-to-date basic and beneficial ownership information is available on a timely basis to competent authorities. The FATF again expresses concern that Jamaica failed to complete its action plan, which fully expired in January 2022. The FATF strongly urges Jamaica to swiftly demonstrate significant progress in completing its action plan by June 2023 or the FATF will consider next steps, which could include calling on its members and urging all jurisdictions to apply enhanced due diligence to business relations and transactions with Jamaica. Since October 2021, when Jordan made a high-level political commitment to work with the FATF and MENAFATF to strengthen the effectiveness of its AML/CFT regime. Jordan has taken positive steps towards improving its AML/CFT regime, including by conducting inspections of reporting entities including FIs and DNFBPs, pursuing money laundering investigations and prosecutions for predicate offences in line with its risk profile, and conducting outreach on TFS obligations. Jordan should continue to work on implementing its action plan to address its strategic deficiencies, including JAMAICA JORDAN
by: (1) completing and disseminating the ML/TF risk assessments of legal persons and virtual assets; (2) applying effective, proportionate, and dissuasive sanctions for noncompliance; (3) implementing a sanctions mechanism for violations of the transparency obligations related to legal persons and arrangements; (4) applying effective, proportionate, and dissuasive sanctions in ML cases; and (5) demonstrating that TFS deficiencies are rectified. In October 2021, 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 conducting AML/CFT trainings for FIs and DNFBPs and enhancing the FIU and LEAs cooperation mechanisms on the use of financial intelligence. Mali should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) implementing the national strategic AML/CFT action plan in line with the NRA; (2) developing and starting to implement a risk based approach for the AML/CFT supervision of all FIs and higher risk DNFBPs and demonstrating effective, proportionate and dissuasive sanctions for noncompliance; (3) conducting a comprehensive assessment of ML/TF risks associated with all types of legal persons; (4) increasing the capacity of the FIU and the LEAs and enhancing their cooperation on the use of financial intelligence; (5) conducting parallel financial investigation; (6) strengthening the capacities of relevant authorities responsible for investigation and prosecution of TF cases; (7) strengthening the legal framework and procedures to implement TFS related MALI
to TF and PF; and (8) implementing a risk-based approach for supervision of the NPO sector to prevent abuse for TF purposes. (Statement from October 2022) In October 2022, Mozambique 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 April 2021, Mozambique has made progress on some of the MER’s recommended actions to improve its system including by finalising its NRA and strengthening its asset confiscation efforts. Mozambique will work to implement its FATF action plan by: (1) ensuring cooperation and coordination amongst relevant authorities to implement risk-based AML/CFT strategies and policies; (2) conducting training for all LEAs on mutual legal assistance to enhance the gathering of evidence or seizure/confiscation of proceeds of crime; (3) providing adequate financial and human resources to supervisors, developing and implementing a risk-based supervision plan; (4) providing adequate resources to the authorities to commence the collection of adequate, accurate and up-to-date beneficial ownership information of legal persons; (5) increasing the human resources of the FIU as well as increasing financial intelligence sent to authorities; (6) demonstrating LEAs capability to effectively investigate ML/TF cases using financial intelligence; (7) conducting a comprehensive TF Risk Assessment and begin implementing a comprehensive national CFT strategy; (8) increasing awareness on TF MOZAMBIQUE
and PF-related TFS; and (9) 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. In February 2023, Nigeria made a high-level political commitment to work with the FATF and GIABA to strengthen the effectiveness of its AML/CFT regime. Since the adoption of its MER in August 2021, Nigeria has made progress on some of the MER’s recommended actions to improve its system including by improving its AML/CFT legislative framework, updating its assessment of inherent ML/TF/PF risks and strengthened its implementation of targeted financial sanctions. Nigeria will work to implement its FATF action plan by: (1) completing its residual ML/TF risk assessment and updating its national AML/CFT strategy to ensure alignment with other national strategies relevant to high-risk predicate offences; (2) enhancing formal and informal international cooperation in line with ML/TF risks; (3) improving AML/CFT risk-based supervision of FIs and DNFBPs and enhancing implementation of preventive measures for high-risk sectors; (4) ensuring that competent authorities have timely access to accurate and up-to-date BO information on legal persons and applying sanctions for breaches of BO obligations; (5) demonstrating an increase in the dissemination of financial intelligence by the FIU and its use by LEAs; (6) demonstrating a sustained increase in ML investigations and prosecutions in line with ML risks; (7) proactively detecting violations of currency declaration obligations and apply appropriate sanctions and maintaining NIGERIA
comprehensive data on frozen, seized, confiscated, and disposed assets; (8) demonstrating sustained increase in investigations and prosecutions of different types of TF activities in line with risk and enhancing interagency cooperation on TF investigations; and (9) conducting risk-based and targeted outreach to NPOs at risk of TF abuse and implementing risk-based monitoring for the subset of NPOs at risk of TF abuse without disrupting or discouraging legitimate NPO activities. Since June 2019, when Panama made a high-level political commitment to work with the FATF and GAFILAT to strengthen the effectiveness of its AML/CFT regime, Panama has taken important steps towards improving its AML/CFT regime, including by demonstrating its ability to investigate and prosecute ML involving foreign tax crimes. However, Panama should continue to take action to fully address remaining measures in its action plan as all timelines have already expired in January 2021. Panama should therefore continue to work on implementing its action plan to address its strategic deficiencies, by ensuring adequate verification, of up-to-date beneficial ownership information by obliged entities and timely access by competent authorities. The FATF again expresses concern that Panama failed to complete its action plan, which fully expired in January 2021. The FATF strongly urges Panama to swiftly complete its action plan by June 2023 or the FATF will consider calling on its members and urging all jurisdictions to apply enhanced due diligence to business relations and transactions with Panama. PANAMA
In June 2021, the Philippines made a high-level political commitment to work with the FATF and APG to strengthen the effectiveness of its AML/CFT regime. The Philippines should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) demonstrating that effective risk-based supervision of DNFBPs is occurring; (2) demonstrating that supervisors are using AML/CFT controls to mitigate risks associated with casino junkets; (3) enhancing and streamlining LEA access to BO information and taking steps to ensure that BO information is accurate and up-to-date; (4) demonstrating an increase in the use of financial intelligence and an increase in ML investigations and prosecutions in line with risk; (5) demonstrating an increase in the identification, investigation and prosecution of TF cases; and (6) enhancing the effectiveness of the targeted financial sanctions framework for both TF and PF by demonstrating that DNFBPs understand their obligations. The FATF notes the Philippines’ continued progress across its action plan, however all deadlines have now expired and work remains. The FATF encourages the Philippines to continue to implement its action plan to address the above-mentioned strategic deficiencies as soon as possible. PHILIPPINES SENEGAL
Since February 2021, when Senegal made a high-level political commitment to work with the FATF and GIABA to strengthen the effectiveness of its AML/CFT regime, Senegal has established a database to collect statistics and data on ML/TF investigations and prosecutions and enhanced the framework for coordination and conduct of TF investigations. Senegal should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) improving compliance by detecting AML/CFT violations and imposing effective, proportionate and dissuasive sanctions against noncompliant DNFBPs; (2) updating and maintaining comprehensive beneficial ownership information on legal persons and arrangements and strengthening the system of sanctions for violations of transparency obligations; (3) enhancing capacity and support for LEAs and prosecutorial authorities involved in combatting TF in line with the 2019 TF National Strategy; and (4) implementing an effective TFS regime related to TF and PF as well as risk-based monitoring and supervision of NPOs. The FATF notes Senegal’s continued progress across its action plan, however all deadlines have now expired and work remains. The FATF urges Senegal to swiftly implement its action plan to address the abovementioned strategic deficiencies as soon as possible. In February 2023, South Africa made a high-level political commitment to work with the FATF and ESAAMLG to strengthen the effectiveness of its SOUTH AFRICA
AML/CFT regime. Since the adoption of its MER in June 2021, South Africa has made significant progress on many of the MER’s recommended actions to improve its system including by developing national AML/CFT policies to address higher risks and newly amending the legal framework for TF and TFS, among others. South Africa will work to implement its FATF action plan by: (1) demonstrating a sustained increase in outbound MLA requests that help facilitate ML/TF investigations and confiscations of different types of assets in line with its risk profile; (2) improving riskbased supervision of DNFBPs and demonstrating that all AML/CFT supervisors apply effective, proportionate, and effective sanctions for noncompliance; (3) ensuring that competent authorities have timely access to accurate and up-to-date BO information on legal persons and arrangements and applying sanctions for breaches of violation by legal persons to BO obligations; (4) demonstrating a sustained increase in law enforcement agencies’ requests for financial intelligence from the FIC for its ML/TF investigations; (5) demonstrate a sustained increase in investigations and prosecutions of serious and complex money laundering and the full range of TF activities in line with its risk profile; (6) enhancing its identification, seizure and confiscation of proceeds and instrumentalities of a wider range of predicate crimes, in line with its risk profile; (7) updating its TF Risk Assessment to inform the implementation of a comprehensive national counter financing of terrorism strategy; and (8) ensuring the effective implementation of targeted financial sanctions and demonstrating an effective mechanism to identify individuals and entities that meet the criteria for domestic designation. SOUTH SUDAN
In June 2021, South Sudan made a high-level political commitment to work with the FATF to strengthen the effectiveness of its AML/CFT regime. South Sudan should continue to work to implement its action plan, including by: (1) conducting a comprehensive review of the AML/CFT Act (2012), with the support of international partners, including technical assistance, to comply with the FATF Standards; (2) becoming a party to and fully implementing the 1988 Vienna Convention, the 2000 Palermo Convention, and the 1999 Terrorist Financing Convention; (3) ensuring that competent authorities are suitably structured and capacitated to implement a risk-based approach to AML/CFT supervision for financial institutions; (4) developing a comprehensive legal framework to collect and verify the accuracy of beneficial ownership information for legal persons; (5) operationalising a fully functioning and independent FIU; (6) establishing and implementing the legal and institutional framework to implement targeted financial sanctions in compliance with United Nations Security Council Resolutions on terrorism and WMD proliferation financing; and (7) commencing implementation of targeted risk-based supervision/monitoring of NPOs at risk of TF abuse. The FATF notes South Sudan’s limited progress across its action plan. The FATF again encourages South Sudan to continue to demonstrate its strong political and institutional commitment to strengthen the effectiveness of its AML/CFT regime, particularly in supporting the lead AML/CFT agency in coordinating national AML/CFT efforts. SYRIA
Since February 2010, when Syria made a high-level political commitment to work with the FATF and MENAFATF to address its strategic AML/CFT deficiencies, Syria has made progress to improve its AML/CFT regime. In June 2014, the FATF determined that Syria had substantially addressed its action plan at a technical level, including by criminalising terrorist financing and establishing procedures for freezing terrorist assets. While the FATF determined that Syria has completed its agreed action plan, due to the security situation, the FATF has been unable to conduct an on-site visit to confirm whether the process of implementing the required reforms and actions has begun and is being sustained. The FATF will continue to monitor the situation, and will conduct an on-site visit at the earliest possible date. (Statement from October 2022) In October 2022, Tanzania 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 April 2021, Tanzania has made progress on some of the MER’s recommended actions to improve its system including by developing legal framework for TF and TFS and disseminating FIU strategic analysis. Tanzania will work to implement its FATF action plan by: (1) improving risk-based supervision of FIs and DNFBPs, including by conducting inspections on a risk-sensitive basis and applying effective, proportionate, and dissuasive TANZANIA
sanctions for non-compliance; (2) demonstrating authorities’ capability to effectively conduct a range of investigations and prosecutions of ML in line with the country’s risk profile; (3) demonstrating that LEAs are taking measures to identify, trace, seize, and confiscate proceeds and instrumentalities of crime; (4) conducting a comprehensive TF Risk Assessment and begin implementing a comprehensive national CFT strategy as well as demonstrating capability to conduct TF investigations and pursue prosecutions in line with the country’s risk profile; (5) increasing awareness of the private sector and competent authorities on TF and PF-related 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. Since October 2021, when Türkiye made a high-level political commitment to work with the FATF to strengthen the effectiveness of its AML/CFT regime, Türkiye has taken further steps towards improving its AML/CFT regime, including by issuing regulations regarding politically exposed persons and guidance to the private sector on detecting terrorist financing, as well as increasing the FIU’s proactive dissemination of financial intelligence. Türkiye should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) increasing on-site inspections by supervisors across all sectors, commensurate with risk; (2) enhancing the use of financial intelligence to support ML investigations; (3) undertaking more complex ML investigations and prosecutions; (4) using statistics on confiscation and TÜRKIYE
terrorist financing to update risk assessments and inform policy; (5) conducting more financial investigations in terrorism cases, prioritising TF investigations and prosecutions related to UNdesignated groups, and ensuring TF investigations are extended to identify financing and support networks; (6) concerning targeted financial sanctions, pursuing outgoing requests to third-countries related to UNdesignated groups, in line with Türkiye’s risk profile; and (7) fully implementing a risk-based approach for the supervision of non-profit organisations to prevent their abuse for terrorist financing, including by taking steps to ensure that audits conducted are risk-based, that supervision does not disrupt or discourage legitimate NPO activity such as fundraising, and that sanctions applied are proportionate to any violations. The FATF continues to monitor that Türkiye’s oversight of the NPO sector is in line with the risk-based approach as set out in the FATF Standards. Since February 2020, when Uganda made a high-level political commitment to work with the FATF and ESAAMLG to strengthen the effectiveness of its AML/CFT regime, Uganda demonstrated progress, including demonstrating LEAs and judicial authorities apply the ML offence consistent with the identified risks, and establishing and implementing policies and procedures for identifying, tracing, seizing and confiscating proceeds and instrumentalities of crime. Uganda should continue to work to implement its action plan to address its strategic deficiencies, including by: (1) developing and implementing riskUGANDA
based supervision of FIs and DNFBPs; (2) ensuring that competent authorities have timely access to accurate basic and beneficial ownership information for legal entities; and (3) addressing the technical deficiencies in the legal framework to implement PF-related targeted financial sanctions. The FATF continues to monitor Uganda’s oversight of the NPO sector to encourage the application of the risk-based approach to supervision of NPOs in line with the FATF Standards and mitigate unintended consequences. The FATF expresses concern that Uganda failed to complete its action plan, which fully expired in May 2022. The FATF strongly urges Uganda to swiftly demonstrate significant progress in completing its action plan by June 2023 or the FATF will consider next steps if there is insufficient progress. Since February 2022, when the United Arab Emirates (UAE) made a high-level political commitment to work with the FATF and MENAFATF to strengthen the effectiveness of its AML/CFT regime, the UAE demonstrated significant progress, including by demonstrating a sustained increase in outbound MLA requests to help facilitate the investigation of TF, ML, and high-risk predicates, showing greater use of financial intelligence to pursue high-risk ML threats, and combating UN sanctions evasion, including by demonstrating a better understanding among the private sector. The UAE should continue to work to implement its FATF action plan by: (1) enhancing and maintaining a UNITED ARAB EMIRATES
shared understanding of the ML/TF risks between the different DNFBP sectors and institutions; (2) showing an increase in the number and quality of STRs filed by FIs and DNFBPs; (3) ensuring a more granular understanding of the risk of abuse of legal persons and, where applicable, legal arrangements, for ML/TF; and (4) demonstrating a sustained increase in effective investigations and prosecutions of different types of ML cases consistent with UAE’s risk profile. Since February 2010, when Yemen made a highlevel political commitment to work with the FATF and MENAFATF to address its strategic AML/CFT deficiencies, Yemen has made progress to improve its AML/CFT regime. In June 2014, the FATF determined that Yemen had substantially addressed its action plan at a technical level, including by: (1) adequately criminalising money laundering and terrorist financing; (2) establishing procedures to identify and freeze terrorist assets; (3) improving its customer due diligence and suspicious transaction reporting requirements; (4) issuing guidance; (5) developing the monitoring and supervisory capacity of the financial sector supervisory authorities and the financial intelligence unit; and (6) establishing a fully operational and effectively functioning financial intelligence unit. While the FATF determined that Yemen has completed its agreed action plan, due to the security situation, the FATF has been unable to conduct an on-site visit to confirm whether the process of implementing YEMEN
the required reforms and actions has begun and is being sustained. The FATF will continue to monitor the situation, and conduct an on-site visit at the earliest possible date. The FATF welcomes Cambodia’s significant progress in improving its AML/CFT regime. Cambodia has strengthened the effectiveness of its AML/CFT regime to meet the commitments in its action plan regarding the strategic deficiencies that the FATF identified in February 2019 related to improvements in the legal framework for international cooperation and preventive measures, riskbased supervision of FIs and DNFBPs, improving the quality and quantity of FIU disseminations, increasing and improving investigation and prosecution of ML and asset confiscation and establishing and implementing a legal framework for PF TFS. Cambodia is therefore no longer subject to the FATF’s increased monitoring process. Cambodia should continue to work with APG to sustain its improvements in its AML/CFT system. JURISDICTIONS NO LONGER SUBJECT TO INCREASED MONITORING BY THE FATF CAMBODIA
The FATF welcomes Morocco’s significant progress in improving its AML/CFT regime. Morocco strengthened the effectiveness of its AML/CFT regime to meet the commitments in its action plan regarding the strategic deficiencies that the FATF identified in February 2021 related to improving its international cooperation mechanisms, strengthening AML/CFT supervision, strengthening transparency of legal persons by ensuring timely access to accurate beneficial ownership information, strengthening the capacities of the FIU, enhancing capacities to conduct ML investigation and confiscate the proceeds of crime and improving effectiveness of the targeted financial sanctions regime. Morocco is therefore no longer subject to the FATF’s increased monitoring process. Morocco should continue to work with MENAFATF to sustain its improvements in its AML/CFT system. MOROCCO
Home Publications Jurisdictions under Increased Monitoring - 21 October 2022 Jurisdictions under Increased Monitoring - 21 October 2022 Publication details Language English Country Albania | Barbados | Burkina Faso | Cambodia | Cayman Islands | Democratic Republic of the Congo | Gibraltar | Haiti | Jamaica | Jordan | Mali | Morocco | Mozambique | Nicaragua | Pakistan | Panama | Philippine | Senegal | South Sudan |Syria | Tanzania | Türkiye | Uganda | United Arab Emirates | Yemen Topic High-risk and other monitored jurisdictions English The FATF Countries Publications Topics Calendars
Jurisdictions No Longer Subject to Increased Monitoring by the FATF Outcomes FATF Plenary, 20-21 October 2022 High-Risk Jurisdictions subject to a Call for Action – 21 October 2022 Paris, 21 October 2022 - Jurisdictions under increased monitoring are actively working with the FATF to address strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing. When the FATF places a jurisdiction under increased monitoring, it means the country has committed to resolve swiftly the identified strategic deficiencies within agreed timeframes and is subject to increased monitoring. This list is often externally referred to as the “grey list”. The FATF and FATF-style regional bodies (FSRBs) continue to work with the jurisdictions below as they report on the progress achieved in addressing their strategic deficiencies. The FATF calls on these jurisdictions to complete their action plans expeditiously and within the agreed timeframes. The FATF welcomes their commitment and will closely monitor their progress. The FATF does not call for the application of enhanced due diligence measures to be applied to these jurisdictions. The FATF Standards do not envisage de-risking, or cutting-off entire classes of customers, but call for the application of a riskbased approach. Therefore, the FATF encourages its members and all jurisdictions to take into account the information presented below in their risk analysis. The FATF identifies additional jurisdictions, on an on-going basis, that have strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing. A number of jurisdictions have not yet been reviewed by the FATF or their FSRBs, but will be in due course. • Nicaragua • Pakistan
Since the start of the COVID-19 pandemic, the FATF has provided some flexibility to jurisdictions not facing immediate deadlines to report progress on a voluntary basis. The following countries had their progress reviewed by the FATF since June 2022: Albania, Barbados, Burkina Faso, Cambodia, Cayman Islands, Haiti, Jamaica, Jordan, Mali, Morocco, Myanmar, Nicaragua, Pakistan, Panama, Philippines, Senegal, South Sudan, Türkiye, UAE, and Uganda. For these countries, updated statements are provided below. Gibraltar chose to defer reporting; thus, the statement issued in June 2022 for that jurisdiction is included below, but it may not necessarily reflect the most recent status of the jurisdiction’s AML/CFT regime. Following review, the FATF now also identifies the Democratic Republic of the Congo, Mozambique, and Tanzania. The FATF welcomes the progress made by these countries in combating money laundering and terrorist financing, despite the challenges posed by COVID-19. Since February 2020, when Albania made a high-level political commitment to work with the FATF and MONEYVAL to strengthen the effectiveness of its AML/CFT regime, Albania has taken steps towards improving its AML/CFT regime, including by enacting an adequate legal framework for violations of company and NPO registration obligations and implementing proportionate and dissuasive sanctions against entities that failed to declare their beneficial owners in the registry by the deadline. Albania should continue to work on implementing its action plan to address its strategic deficiencies, including by increasing the number of money laundering indictments that it brings to court for prosecution. The FATF expresses concern that Albania failed to complete its action plan, which fully expired in February 2022. The FATF strongly urges Albania to swiftly demonstrate significant progress in completing its action plan by February 2023 or the FATF will consider next steps if there is insufficient progress. ALBANIA
Additionally, the FATF expresses concern that Albania’s plans for a possible Voluntary Tax Compliance (VTC) programme do not comply with the FATF’s principles for managing the AML/CFT implications of VTCs or FATF’s best practices for such programmes. Albania should revise its draft VTC law and work with MONEYVAL to ensure that any VTC law passed or implemented has adequate safeguards to prevent the potential for abuse of the programme for money laundering or terrorist financing purposes. Since February 2020, when Barbados made a high-level political commitment to work with the FATF and CFATF to strengthen the effectiveness of its AML/CFT regime, Barbados has taken steps towards improving its AML/CFT regime, including by, demonstrating the ability to enforce breaches of BO requirements, strengthening the relationship between the FIU and LEAs, improving the ML database, and demonstrating progress in the investigation, seizure and forfeiture of cash and assets. Barbados should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) taking appropriate measures to prevent legal persons and arrangements from being misused for criminal purposes, and ensuring that accurate and up-to-date basic and beneficial ownership information is available on a timely basis; (2) demonstrating that ML investigations and prosecutions are in line with the country’s risk profile; (3) further pursuing confiscation in ML cases, including by repatriating or sharing confiscated assets with other countries. The FATF urges Barbados to swiftly complete its action plan as all deadlines have now expired and to address the above-mentioned strategic deficiencies by February 2023. BARBADOS
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 strengthening its efforts to pursue confiscation as a policy objective. Burkina Faso should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) updating its understanding of ML/TF risks, including through the revision of the national risk assessment in line with the sectoral priorities identified in its national strategy; (2) seeking mutual legal assistance (MLA) and other forms of international cooperation in line with its risk profile; (3) strengthening of resource capacities of all AML/CFT supervisory authorities and implementing risk based supervision of FIs and DNFBPs; (4) maintaining comprehensive and updated basic and beneficial ownership information and strengthening the system of sanctions for violations of transparency obligations; (5) increasing the diversity of STR reporting; (6) enhancing the resources of the FIU to provide additional capacity building and training to FIs, DNFBPs and the investigative and judicial authorities; (7) conduct training for LEAs, prosecutors and other relevant authorities; (8) enhancing capacity and support for LEAs and prosecutorial authorities involved in combatting TF, in line with the TF National Strategy; and (9) implementing an effective targeted financial sanctions regime related to TF and PF as well as risk-based monitoring and supervision of NPOs. In February 2019, Cambodia made a high-level political commitment to work with the FATF and APG to strengthen the effectiveness of its AML/CFT regime. At its October 2022 Plenary, the FATF made the BURKINA FASO CAMBODIA
initial determination that Cambodia has substantially completed its action plan and warrants an on-site visit to verify that the implementation of Cambodia’s AML/CFT reforms has begun and is being sustained, and that the necessary political commitment remains in place to sustain implementation and improvement in the future. Cambodia has made a number of key reforms, including to improve: (1) MLA law and providing training on MLA to prosecutors and judges; (2) risk-based supervision for FIs and DNFBPs; (3) the legal framework on preventive measures and conducting outreach to the casino, real-estate and MVTS sectors; (4) the quality and quantity of FIU disseminations, demonstrating an increase in ML investigations in line with risk; (5) its effectiveness in asset confiscation; and (6) establishing a legal framework for implementing UN sanctions related to targeted financial sanctions for PF and providing training to strengthen the skills of competent authorities to implement TFS for PF. The FATF will continue to monitor the COVID-19 situation and conduct an on-site visit at the earliest possible date. Since February 2021, when the Cayman Islands made a high-level political commitment to work with the FATF and CFATF to strengthen the effectiveness of its AML/CFT regime, the Cayman Islands has taken steps towards improving its AML/CFT regime, including by imposing adequate and effective sanctions in cases where relevant parties (including legal persons) do not file accurate, adequate and up-to-date beneficial ownership information in line with those requirements. The Cayman Islands should continue to work on implementing its action plan to address its strategic deficiencies, including by demonstrating that they are prosecuting all types of money laundering cases in line with the jurisdiction’s risk profile and that such prosecutions are resulting in the application of dissuasive, effective, and proportionate sanctions. THE CAYMAN ISLANDS
The FATF urges the Cayman Islands to swiftly complete its action plan as all deadlines have now expired and to address the abovementioned strategic deficiency by February 2023. In October 2022, the DRC made a high-level political commitment to work with the FATF and GABAC to strengthen the effectiveness of its AML/CFT regime. Since the adoption of its MER in October 2020, the DRC has made progress on some of the MER’s recommended actions including making confiscation of proceeds of crime a policy priority. The DRC will work to implement its FATF action plan by: (1) finalising the NRA on ML and TF and adopting an AML/CFT national strategy; (2) designating supervisory authorities for all DNFBP sectors, and developing and implementing a risk-based supervision plan; (3) adequately resourcing the FIU, and build its capacity to conduct operational and strategic analysis; (4) strengthening the capabilities of authorities involved in the investigation and prosecution of ML and TF; and (5) demonstrating effective implementation of TF and PFrelated TFS. (Statement from June 2022) In June 2022, Gibraltar 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 MER in December 2019, Gibraltar has made progress on a significant number of its MER’s recommended actions, such as completing a new national risk assessment, addressing the technical deficiencies in relation to BOrelated record keeping, introducing transparency requirements for THE DEMOCRATIC REPUBLIC OF THE CONGO GIBRALTAR
nominee shareholders and directors, strengthening the financial intelligence unit, and refining its ML investigation policy in line with risks. Gibraltar should work on implementing its action plan, including by: (1) ensuring that supervisory authorities for non-bank financial institutions and DNFBPs use a range of effective, proportionate, and dissuasive sanctions for AML/CFT breaches; and (2) demonstrating that it is more actively and successfully pursuing final confiscation judgements, through criminal or civil proceedings based on financial investigations. In June 2021, Haiti made a high-level political commitment to work with the FATF and CFATF to strengthen the effectiveness of its AML/CFT regime. 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) facilitating information sharing with relevant foreign counterparts; (3) addressing the technical deficiencies in its legal and regulatory framework that impede the implementation of AML/CFT preventive measures and implementing risk-based AML/CFT supervision for all financial institutions and DNFBPs deemed to constitute a higher ML/TF risk; (4) ensuring basic and beneficial ownership information are maintained and accessible in a timely manner; (5) ensuring a better use of financial intelligence and other relevant information by competent authorities for combatting ML and TF; (6) addressing the technical deficiencies in its ML offence and demonstrating authorities are identifying, investigating and prosecuting ML cases in a manner consistent with Haiti’s risk profile; (7) demonstrating an increase of identification, tracing and recovery of proceeds of crimes; (8) addressing the technical deficiencies in its TF offence and targeted financial sanctions regime; and (9) conducting appropriate risk-based monitoring of NPOs vulnerable HAITI
to TF abuse without disrupting or discouraging legitimate NPO activities. In February 2020, Jamaica made a high-level political commitment to work with the FATF and CFATF to strengthen the effectiveness of its AML/CFT regime. Jamaica should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) including all FIs and DNFBPs in the AML/CFT regime and ensuring adequate, risk-based supervision in all sectors; (2) taking appropriate measures to prevent legal persons and arrangements from being misused for criminal purposes, and ensuring that accurate and up-todate basic and beneficial ownership information is available on a timely basis to competent authorities; and (3) implementing a riskbased approach for supervision of the NPO sector to prevent abuse for TF purposes. The FATF expresses concern that Jamaica failed to complete its action plan, which fully expired in January 2022. The FATF strongly urges Jamaica to swiftly demonstrate significant progress in completing its action plan by February 2023 or the FATF will consider next steps if there is insufficient progress. Since October 2021, when Jordan made a high-level political commitment to work with the FATF and MENAFATF to strengthen the effectiveness of its AML/CFT regime. Jordan has taken steps towards improving its AML/CFT regime, including by strengthening its legal and operational TF-related TFS framework, increasing capacity for riskbased DNFBP supervision, making basic and beneficial ownership JAMAICA JORDAN
information accessible by competent authorities, maintaining statistics on ML investigations and prosecution and strengthening its legal framework with respect to confiscation. Jordan should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) completing and disseminating the ML/TF risk assessments of legal persons and virtual assets; (2) Improving risk based supervision and applying effective, proportionate, and dissuasive sanctions for noncompliance; (3) Conducting training and awareness raising programs for DNFBPS on their AML/CFT obligations, particularly with regard to filing and submitting STRS; (4) Maintaining comprehensive and updated basic and beneficial ownership information on legal persons and legal arrangements; (5) Pursuing money laundering investigations and prosecutions, including through parallel financial investigations, for predicate offences in line with the risk identified in the NRA; (6) Monitoring and effectively supervising the compliance of FIs and DNFBPS with TFS obligations; and (7) Developing and implementing a risk-based approach for supervision of the NPO sector to prevent abuse for TF purposes. In October 2021, Mali made a high-level political commitment to work with the FATF and GIABA to strengthen the effectiveness of its AML/CFT regime. Mali should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) implementing the national strategic AML/CFT action plan in line with the NRA; (2) developing and starting to implement a risk based approach for the AML/CFT supervision of all FIs and higher risk DNFBPs and demonstrating effective, proportionate and dissuasive sanctions for noncompliance; (3) conducting a comprehensive assessment of ML/TF risks associated with all types of legal persons; (4) increasing the capacity of the FIU and the LEAs and enhancing their cooperation on the use of financial intelligence; (5) ensuring relevant competent authorities are involved in investigation and MALI
prosecution of ML; (6) strengthening the capacities of relevant authorities responsible for investigation and prosecution of TF cases; (7) establishing a legal framework and procedures to implement TFS related to TF and PF; and (8) implementing a risk-based approach for supervision of the NPO sector to prevent abuse for TF purposes. In February 2021, Morocco made a high-level political commitment to work with the FATF and MENAFATF to strengthen the effectiveness of its AML/CFT regime. At its October 2022 plenary, the FATF has made the initial determination that Morocco has substantially completed its action plan and warrants an on-site assessment to verify that the implementation of Morocco’s AML/CFT reforms has begun and is being sustained, and that the necessary political commitment remains in place to sustain implementation in the future. Morocco has made the following key reforms, including: (1) improving risk-based supervision and taking remedial actions and applying effective, proportionate and dissuasive sanctions for non-compliance; (2) strengthening its TFS framework and monitoring FIs and DNFBP’s compliance with TFS obligations; (3) undertaking and sharing the results of the risk assessment on the misuse of all types of legal persons with the private sector and the competent authorities; (4) increasing the diversity of suspicious transactions reporting; and (5) establishing asset seizing and confiscation procedures. The FATF will continue to monitor the COVID-19 situation and conduct an on-site visit at the earliest possible date. MOROCCO
In October 2022, Mozambique 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 April 2021, Mozambique has made progress on some of the MER’s recommended actions to improve its system including by finalising its NRA and strengthening its asset confiscation efforts. Mozambique will work to implement its FATF action plan by: (1) ensuring cooperation and coordination amongst relevant authorities to implement riskbased AML/CFT strategies and policies; (2) conducting training for all LEAs on mutual legal assistance to enhance the gathering of evidence or seizure/confiscation of proceeds of crime; (3) providing adequate financial and human resources to supervisors, developing and implementing a risk-based supervision plan; (4) providing adequate resources to the authorities to commence the collection of adequate, accurate and up-to-date beneficial ownership information of legal persons; (5) increasing the human resources of the FIU as well as increasing financial intelligence sent to authorities; (6) demonstrating LEAs capability to effectively investigate ML/TF cases using financial intelligence; (7) conducting a comprehensive TF Risk Assessment and begin implementing a comprehensive national CFT strategy; (8) increasing awareness on TF and PF-related TFS; and (9) 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. Since June 2019, when Panama made a high-level political commitment to work with the FATF and GAFILAT to strengthen the effectiveness of its AML/CFT regime, Panama has taken important steps towards improving its AML/CFT regime, including by ensuring MOZAMBIQUE PANAMA
effective, proportionate, and dissuasive sanctions in response to AML/CFT violations. However, Panama should continue to take urgent action to fully address remaining measures in its action plan as all timelines have already expired in January 2021. Panama should therefore continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) ensuring adequate verification, of up-to-date beneficial ownership information by obliged entities and timely access by competent authorities, establishing effective mechanisms to monitor the activities of offshore entities, and further implementing the specific measures to prevent the misuse of nominee shareholders and directors; and (2) demonstrating its ability to investigate and prosecute ML involving foreign tax crimes. The FATF again expresses significant concern that Panama failed to complete its action plan, which fully expired in January 2021. The FATF strongly urges Panama to swiftly complete its action plan by February 2023 or the FATF will consider calling on its members and urging all jurisdictions to apply enhanced due diligence to business relations and transactions with Panama. Since June 2021, when the Philippines made a high-level political commitment to work with the FATF and APG to strengthen the effectiveness of its AML/CFT regime, the Philippines has taken steps towards improving its AML/CFT regime, including by demonstrating that appropriate measures are being taken with respect to the NPO sector and implementing supervision for targeted financial sanctions. The Philippines should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) demonstrating that effective risk-based supervision of DNFBPs is occurring; (2) demonstrating that supervisors are using AML/CFT controls to mitigate risks associated with casino junkets; (3) enhancing PHILIPPINES
and streamlining LEA access to BO information and taking steps to ensure that BO information is accurate and up-to-date; (4) demonstrating an increase in the use of financial intelligence and an increase in ML investigations and prosecutions in line with risk; (5) demonstrating an increase in the identification, investigation and prosecution of TF cases; and (6) enhancing the effectiveness of the targeted financial sanctions framework for both TF and PF by demonstrating that DNFBPs understand their obligations. Since February 2021, when Senegal made a high-level political commitment to work with the FATF and GIABA to strengthen the effectiveness of its AML/CFT regime, Senegal has taken steps towards improving its AML/CFT regime, including by ensuring consistent understanding of ML/TF risks across relevant authorities through training and outreach, and seeking MLA and other forms of international cooperation. Senegal should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) improving compliance by detecting AML/CFT violations and imposing effective, proportionate and dissuasive sanctions against non-compliant entities; (2) updating and maintaining comprehensive beneficial ownership information on legal persons and arrangements and strengthening the system of sanctions for violations of transparency obligations; (3) strengthening the authorities understanding of TF risks and enhancing capacity and support for LEAs and prosecutorial authorities involved in combatting TF in line with the 2019 TF National Strategy; and (4) implementing an effective TFS regime related to TF and PF as well as risk-based monitoring and supervision of NPOs. The FATF notes Senegal’s continued progress across its action plan, however all deadlines have now expired and work remains. The FATF encourages Senegal to continue to implement its action plan to SENEGAL
address the above-mentioned strategic deficiencies as soon as possible. In June 2021, South Sudan made a high-level political commitment to work with the FATF to strengthen the effectiveness of its AML/CFT regime. South Sudan became a member of ESAAMLG in September 2022 and committed to undergo a mutual evaluation. South Sudan should continue to work to implement its action plan, including by: (1) conducting a comprehensive review of the AML/CFT Act (2012), with the support of international partners, including technical assistance, to comply with the FATF Standards; (2) becoming a party to and fully implementing the 1988 Vienna Convention, the 2000 Palermo Convention, and the 1999 Terrorist Financing Convention; (3) ensuring that competent authorities are suitably structured and capacitated to implement a risk-based approach to AML/CFT supervision for financial institutions; (4) developing a comprehensive legal framework to collect and verify the accuracy of beneficial ownership information for legal persons; (5) operationalising a fully functioning and independent FIU; (6) establishing and implementing the legal and institutional framework to implement targeted financial sanctions in compliance with United Nations Security Council Resolutions on terrorism and WMD proliferation financing; and (7) commencing implementation of targeted risk-based supervision/monitoring of NPOs at risk of TF abuse. The FATF notes South Sudan’s limited progress across its action plan. The FATF again encourages South Sudan to continue to demonstrate its strong political and institutional commitment to strengthen the effectiveness of its AML/CFT regime, particularly in supporting the lead AML/CFT agency in coordinating national AML/CFT efforts. SOUTH SUDAN
Since February 2010, when Syria made a high-level political commitment to work with the FATF and MENAFATF to address its strategic AML/CFT deficiencies, Syria has made progress to improve its AML/CFT regime. In June 2014, the FATF determined that Syria had substantially addressed its action plan at a technical level, including by criminalising terrorist financing and establishing procedures for freezing terrorist assets. While the FATF determined that Syria has completed its agreed action plan, due to the security situation, the FATF has been unable to conduct an on-site visit to confirm whether the process of implementing the required reforms and actions has begun and is being sustained. The FATF will continue to monitor the situation, and will conduct an on-site visit at the earliest possible date. In October 2022, Tanzania 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 April 2021, Tanzania has made progress on some of the MER’s recommended actions to improve its system including by developing legal framework for TF and TFS and disseminating FIU strategic analysis. Tanzania will work to implement its FATF action plan by: (1) improving risk-based supervision of FIs and DNFBPs, including by conducting inspections on a risk-sensitive basis and applying effective, proportionate, and dissuasive sanctions for non-compliance; (2) demonstrating authorities’ capability to effectively conduct a range of investigations and prosecutions of ML in line with the country’s risk profile; (3) demonstrating that LEAs are taking measures to identify, trace, seize, and confiscate proceeds and instrumentalities of crime; (4) SYRIA TANZANIA
conducting a comprehensive TF Risk Assessment and begin implementing a comprehensive national CFT strategy as well as demonstrating capability to conduct TF investigations and pursue prosecutions in line with the country’s risk profile; (5) increasing awareness of the private sector and competent authorities on TF and PF-related 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. Since October 2021, when Türkiye made a high-level political commitment to work with the FATF to strengthen the effectiveness of its AML/CFT regime, Türkiye has taken further steps towards improving its AML/CFT regime, including by increasing the human resources at the FIU to conduct analysis and pursuing a number of domestic designations under UNSCR 1373 to target terrorist financing in line with Türkiye’s risk profile. Türkiye should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) increasing on-site inspections by supervisors across all sectors, commensurate with risk; (2) enhancing the use of financial intelligence to support ML investigations and increasing proactive disseminations by the FIU; (3) undertaking more complex money laundering investigations and prosecutions; (4) setting out clear responsibilities and measurable performance objectives and metrics for the authorities responsible for recovering criminal assets and pursuing terrorism financing cases and using statistics to update risk assessments and inform policy; (5) conducting more financial investigations in terrorism cases, prioritising TF investigations and prosecutions related to UN-designated groups, and ensuring TF investigations are extended to identify financing and support networks; (6) concerning targeted financial sanctions, pursuing outgoing requests to third-countries related to UN-designated groups, TÜRKIYE
in line with Türkiye’s risk profile; and (7) to fully implement a riskbased approach to supervision of non-profit organisations to prevent their abuse for terrorist financing, taking steps to ensure that audits conducted are risk-based, that supervision does not disrupt or discourage legitimate NPO activity such as fundraising, and that sanctions applied are proportionate to any violations. The FATF continues to monitor Türkiye’s oversight of the NPO sector. Türkiye is urged to demonstrate the implementation of the risk-based approach to supervision of NPOs in line with the FATF Standards. Since February 2020, when Uganda made a high-level political commitment to work with the FATF and ESAAMLG to strengthen the effectiveness of its AML/CFT regime, Uganda demonstrated progress, including completing the ML/TF risk assessment of legal persons and arrangements. Uganda should continue to work to implement its action plan to address its strategic deficiencies, including by: (1) developing and implementing risk-based supervision of FIs and DNFBPs; (2) ensuring that competent authorities have timely access to accurate basic and beneficial ownership information for legal entities; (3) demonstrating LEAs and judicial authorities apply the ML offence consistent with the identified risks; (4) establishing and implementing policies and procedures for identifying, tracing, seizing and confiscating proceeds and instrumentalities of crime; and (5) addressing the technical deficiencies in the legal framework to implement PF-related targeted financial sanctions. The FATF continues to monitor Uganda’s oversight of the NPO sector to encourage the application of the risk-based approach to supervision of NPOs in line with the FATF Standards and mitigate unintended consequences. The FATF strongly urges Uganda to swiftly implement its action plan to address the above-mentioned strategic deficiencies as soon as possible as all deadlines expired in May 2022. UGANDA
Since February 2022, when the United Arab Emirates (UAE) made a high-level political commitment to work with the FATF and MENAFATF to strengthen the effectiveness of its AML/CFT regime, the UAE demonstrated positive progress, including by providing additional resources to the FIU to strengthen the FIU analysis and provide financial intelligence to LEAs and the Public Prosecutors for combating of high-risk ML threats. The UAE should continue to work to implement its FATF action plan by: (1) demonstrating through case studies and statistics a sustained increase in outbound MLA requests to help facilitate investigation of TF, ML, and high-risk predicates; (2) enhancing and maintaining a shared understanding of the ML/TF risks between the different DNFBP sectors and institutions; (3) showing an increase in the number and quality of STRs filed by FIs and DNFBPs; (4) ensuring a more granular understanding of the risk of abuse of legal persons and, where applicable, legal arrangements, for ML/TF; (5) demonstrate greater use of financial intelligence to pursue high-risk ML threats; and demonstrating a sustained increase in effective investigations and prosecutions of different types of ML cases consistent with UAE’s risk profile; and (6) proactively identifying and combating sanctions evasion, including by demonstrating a better understanding of sanctions evasion among the private sector. Since February 2010, when Yemen made a high-level political commitment to work with the FATF and MENAFATF to address its strategic AML/CFT deficiencies, Yemen has made progress to UNITED ARAB EMIRATES YEMEN
improve its AML/CFT regime. In June 2014, the FATF determined that Yemen had substantially addressed its action plan at a technical level, including by: (1) adequately criminalising money laundering and terrorist financing; (2) establishing procedures to identify and freeze terrorist assets; (3) improving its customer due diligence and suspicious transaction reporting requirements; (4) issuing guidance; (5) developing the monitoring and supervisory capacity of the financial sector supervisory authorities and the financial intelligence unit; and (6) establishing a fully operational and effectively functioning financial intelligence unit. While the FATF determined that Yemen has completed its agreed action plan, due to the security situation, the FATF has been unable to conduct an on-site visit to confirm whether the process of implementing the required reforms and actions has begun and is being sustained. The FATF will continue to monitor the situation, and conduct an on-site visit at the earliest possible date. Nicaragua The FATF notes Nicaragua’s progress in improving the elements of its AML/CFT regime covered by its action plan. Nicaragua has addressed technical deficiencies to meet the commitments of its action plan regarding strategic deficiencies in the areas that the FATF identified in February 2020. Nicaragua is therefore no longer subject to the FATF’s increased monitoring process. However, the FATF is strongly concerned by the potential misapplication of the FATF Standards resulting in the suppression of Nicaragua’s non-profit sector. Nicaragua JURISDICTIONS NO LONGER SUBJECT TO INCREASED MONITORING BY THE FATF
should continue to work with GAFILAT to improve further its AML/CFT regime, including by ensuring its oversight of NPOs is risk-based and in line with the FATF Standards. Nicaragua is strongly encouraged to continue cooperating with GAFILAT on this issue. Pakistan The FATF welcomes Pakistan’s significant progress in improving its AML/CFT regime. Pakistan has strengthened the effectiveness of its AML/CFT regime and addressed technical deficiencies to meet the commitments of its action plans regarding strategic deficiencies that the FATF identified in June 2018 and June 2021, the latter of which was completed in advance of the deadlines, encompassing 34 action items in total. Pakistan is therefore no longer subject to the FATF’s increased monitoring process. Pakistan will continue to work with APG to further improve its AML/CFT system. Discover The FATF ↙ Countries ↙ Publications ↙ Calendars ↙