In a new advisory, the U.S. Treasury Department's Financial Crimes Enforcement Network ("FinCEN") reminded financial institutions of two documents recently amended by the Financial Action Task Force ("FATF") that raise anti-money laundering or terrorism concerns. The two documents are: (i) the FATF public statement, which focuses on North Korea and Iran as jurisdictions to which countermeasures should be applied and/or that are subject to enhanced due diligence as a result of their deficiencies; and (ii) the "Improving Global AML/CFT Compliance: On-going Process" document, which lists Ethiopia, Serbia, Sri Lanka, Syria, Trinidad and Tobago, Tunisia, Yemen and Pakistan as jurisdictions that have strategic AML terrorism-related deficiencies. FinCEN cautions that "the changes may affect U.S. financial institutions' obligations and risk based approaches with respect to relevant jurisdictions."
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