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FinCEN Updates AML/CFT Deficiencies List

The Financial Crimes Enforcement Network ("FinCEN") provided notice to financial institutions that the Financial Action Task Force ("FATF") recently updated its list of jurisdictions with strategic deficiencies regarding anti-money laundering and combating the financing of terrorism ("AML/CFT"). Changes to the FATF list may affect U.S. financial institutions' risk-based due diligence obligations concerning the affected jurisdictions.

The FATF Public Statement, published on February 23, 2018, identified (i) the Democratic People's Republic of Korea ("DPRK") for countermeasures and (ii) Iran for continued enhanced due diligence. Neither of these classifications represents a change in status from previous advisories. FinCEN reminded institutions of restrictions and prohibitions in connection with correspondent accounts with banks licensed by the DPRK or Iran.

FinCEN also identified the following jurisdictions as having strategic AML/CFT deficiencies: Ethiopia, Iraq, Serbia, Sri Lanka, Syria, Trinidad and Tobago, Tunisia, Vanuatu, and Yemen.

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