On September 21, the Financial Crimes Enforcement Network (FinCEN) issued an advisory reminding financial institutions that, on June 29, the Financial Action Task Force (FAFT) updated two documents that each list jurisdictions identified as having “strategic deficiencies” in their anti-money laundering and combatting the financing of terrorism (AML/CFT) regimes. The first document, the FATF Public Statement, identifies two jurisdictions, the Democratic People’s Republic of Korea and Iran, that are subject to countermeasures and/or enhanced due diligence (EDD) due to their strategic AML/CFT deficiencies. The second document, the Improving Global AML/CFT Compliance: On-going Process, identifies jurisdictions with strategic AML/CFT deficiencies. As further described in the document, FAFT identified the following jurisdictions as having developed action plans to address their AML/CFT deficiencies: Ethiopia, Serbia, Sri Lanka, Syria, Trinidad and Tobago, Tunisia, and Yemen. Notably, Pakistan has been added to the list based on FATF-identified AML/CFT deficiencies, whereas Iraq and Vanuatu have been removed from the list due to “significant progress in improving its AML/CFT regime . . . [and] establish[ing] the legal and regulatory framework to meet the commitments in its action plan.” FinCEN urges financial institutions to consider both the FATF Public Statement and the Improving Global AML/CFT Compliance: On-going Process documents when reviewing due diligence obligations and risk-based policies, procedures, and practices.
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FinCEN advisory reminds financial institutions about recent updates to the lists of FATF-identified jurisdictions with AML/CFT deficiencies
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