FinCEN updates FATF-identified jurisdictions with AML/CFT deficiencies
On July 14, the Financial Crimes Enforcement Network (FinCEN) issued an advisory to inform financial institutions of updates to the Financial Action Task Force (FATF)-identified jurisdictions with “strategic deficiencies” in their anti-money laundering and combating the financing of terrorism (AML/CFT) and counter-proliferation financing deficiencies. FATF notes that in response to measures taken by countries in response to the Covid-19 pandemic, it has temporarily paused reviewing most counties with strategic deficiencies. The advisory reminds members that its February 2020 statement High-Risk Jurisdictions Subject to a Call for Action remains in effect and urges “all jurisdictions to impose countermeasures on Iran and the Democratic People’s Republic of Korea (DPRK) to protect the international financial system from significant strategic deficiencies in their AML/CFT regimes.” The advisory also emphasizes that financial institutions should consider the Jurisdictions under Increased Monitoring document and consult the list of identified countries when reviewing due diligence obligations and risk-based policies, procedures, and practices. The advisory also outlines AML program risk assessment considerations, as well as suspicious activity report filing guidance.