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FinCEN Issues Advisory on AML/CFT Deficiencies List

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

The FATF Public Statement, which was published on October 19, 2018, 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 or Iran.

FinCEN also identified the following jurisdictions as having strategic AML/CFT deficiencies: The Bahamas, Botswana, Ethiopia, Ghana, Pakistan, Serbia, Sri Lanka, Syria, Tunisia, Yemen, and Trinidad and Tobago.

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