FinCEN advised financial institutions on recent updates to the Financial Action Task Force ("FATF") list of jurisdictions with strategic AML and Combating the Financing of Terrorism ("AML/CFT") deficiencies. FinCEN stated that changes to the FATF list may affect U.S. financial institutions' risk-based due diligence obligations concerning the affected jurisdictions.
The FATF's "High-Risk Jurisdictions Subject to a Call for Action," published on February 21, 2020, remains in effect. As previously covered, the FATF called for (i) enhanced due diligence and countermeasures with respect to the Democratic People's Republic of Korea (or "DPRK") and (ii) enhanced due diligence and renewed countermeasures with respect to Iran.
The FATF updated its "Jurisdictions under Increased Monitoring" on October 23, 2020 to remove Iceland and Mongolia from the list after determining from on-site visits that each jurisdiction has implemented reforms to its AML/CFT regimes. The countries that remain on the list are Albania, The Bahamas, Barbados, Botswana, Burma (Myanmar), Cambodia, Ghana, Jamaica, Mauritius, Nicaragua, Pakistan, Panama, Syria, Uganda, Yemen and Zimbabwe.
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