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FinCEN Updates AML/CFT Deficiencies List

In an Advisory to financial institutions on recent updates to the Financial Action Task Force ("FATF") list of jurisdictions with strategic anti-money laundering and combating the financing of terrorism ("AML/CFT") deficiencies, the Financial Crimes Enforcement Network ("FinCEN") stated that changes to the FATF list may affect U.S. financial institutions' risk-based due diligence obligations concerning the affected jurisdictions.

In a Public Statement, which was published on June 21, 2019, FATF calls for (i) countermeasures against the Democratic People's Republic of Korea ("DPRK") and (ii) enhanced due diligence with respect to Iran. Neither of these classifications represents a change in status from recent FATF public statements. FinCEN reminded institutions of restrictions and prohibitions in connection with correspondent accounts of banks licensed by the DPRK.

FinCEN also identified the following jurisdictions as having strategic AML/CFT deficiencies: The Bahamas, Botswana, Cambodia, Ethiopia, Ghana, Pakistan, Panama, Sri Lanka, Syria, Trinidad and Tobago, Tunisia and Yemen. Panama is the most recent addition to the list; Serbia has been removed.

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