FinCEN Issues Advisory on FATF's List of Jurisdictions with AML/CFT Deficiencies

Anti-Money Laundering FinCEN FATF Combating the Financing of Terrorism Agency Rule-Making & Guidance

On July 20, FinCEN issued an advisory to financial institutions with updates to the Financial Action Task Force’s (FATF) list of jurisdictions containing strategic anti-money laundering/counter-terrorist financing (AML/CFT) deficiencies. According to FinCEN’s Advisory, on June 26, FATF updated two documents to reflect changes that have the potential to affect U.S. financial institutions’ due diligence obligations and risk-based policies, procedures, and practices. The first document, the FATF Public Statement, identifies jurisdictions that are subject to Enhanced Due Diligence or countermeasures due to the jurisdiction’s AML/CFT deficiencies. Revisions to the FATF Public Statement include the removal of Ecuador from the Public Statement because of progress in addressing its FATF action plan. Ecuador now appears on the list of jurisdictions requiring general due diligence. The second document to be updated, Improving Global AML/CFT Compliance: On-going Process, identifies new jurisdictions with AML/CFT deficiencies. Bosnia and Herzegovina have been downgraded to the Improving Global AML/CFT Compliance: On-going Process document due to its “strategic deficiencies in its AML/CFT regime." However, the country has made a “high-level political commitment” to work with FATF and regional authorities to address their deficiencies. Indonesia was removed from the listing and monitoring process, according to the Advisory, for “its significant progress in establishing the legal and regulatory framework to address all or nearly all of its strategic AML/CFT deficiencies.”