FATF Updates List of Jurisdictions with AML/CFT/CPF Deficiencies

The Financial Action Task Force ("FATF") updated its list of jurisdictions with strategic AML/CFT and counter-proliferation deficiencies. FinCEN notified U.S. financial institutions that they "should consider the FATF's stance toward these jurisdictions when reviewing their obligations and risk-based policies, procedures, and practices."

Following an update to the list of jurisdictions in June 2022 (see previous coverage), the FATF provided country progress reports for: Albania, Barbados, Burkina Faso, Cambodia, Cayman Islands, the Democratic Republic of the Congo, Gibraltar, Haiti, Jamaica, Jordan, Mali, Morocco, Mozambique, Panama, Philippines, Senegal, South Sudan, Syria, Tanzania, Turkey, United Arab Emirates and Uganda.

Changes to the "Jurisdictions under Increased Monitoring" list include:

• adding the Democratic Republic of the Congo, Mozambique and Tanzania to the list of jurisdictions under increased monitoring; and

• removing Nicaragua and Pakistan from the same list.

FinCEN also confirmed that the FATF's list of "High-Risk Jurisdictions subject to a Call for Action" - which calls for enhanced due diligence and countermeasures with respect to the Democratic People's Republic of Korea and Iran - remains in effect. FinCEN noted that the FATF added Burma to this list and called for enhanced due diligence, but not countermeasures. FinCEN reminded U.S. financial institutions of their due diligence obligations with regard to correspondent accounts at foreign financial institutions.