Apparently keeping active during these turbulent times, the US Financial Crimes Enforcement Network (FinCen) issued an advisory on 26 March to give financial institutions guidance on their obligations with respect to transactions involving countries on the FATF's lists for strategic deficiencies in anti-money laundering and counter-terrorist financing regimes (AML/CFT).
The Financial Action Task Force (FATF) is an inter-governmental organisation which sets the global standards for countries to implement AML/CFT laws and regulations. As part of its role, FATF releases two lists of countries:
- High risk jurisdictions subject to a call to action, known colloquially as the 'black list'.
- Jurisdictions under increased monitoring, known as the 'grey list'.
The two countries on the black list are North Korea and Iran, and FinCen reminds US financial institutions of the extensive restrictions on transactions with or involving persons in these countries.
The grey list includes: Albania, The Bahamas, Barbados, Botswana, Burma (Myanmar), Cambodia, Ghana, Iceland, Jamaica, Mauritius, Mongolia, Nicaragua, Pakistan, Panama, Syria, Uganda, Yemen, and Zimbabwe.
US financial institutions must take into account the strategic deficiencies in these countries' AML/CFT regimes in their risk assessments and risk-based due diligence procedures applied to transactions involving these countries.
FinCEN is issuing this advisory to inform financial institutions of updates to the FATF list of jurisdictions with strategic AML/CFT deficiencies. Financial institutions should be aware of these changes, which may affect their obligations and risk-based approaches with respect to these jurisdictions.