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Financial Services Law Insights and Observations

FinCEN issues statements on its lists of jurisdictions with AML/CFT/CPF deficiencies

Financial Crimes Anti-Money Laundering Combating the Financing of Terrorism Combating Weapons of Mass Destruction Proliferation Financing FATF FinCEN Of Interest to Non-US Persons

Financial Crimes

On June 23, FinCEN announced that the Financial Action Task Force (FATF) issued public statements updating its lists of jurisdictions with strategic deficiencies in anti-money laundering (AML), countering the financing of terrorism (CFT), and countering the financing of proliferation of weapons of mass destructions (CPF). FATF’s statements include (i) Jurisdictions under Increased Monitoring, “which publicly identifies jurisdictions with strategic deficiencies in their AML/CFT/CPF regimes that have committed to, or are actively working with, the FATF to address those deficiencies in accordance with an agreed upon timeline,” and (ii) High-Risk Jurisdictions Subject to a Call for Action, “which publicly identifies jurisdictions with significant strategic deficiencies in their AML/CFT/CPF regimes and calls on all FATF members to apply enhanced due diligence, and, in the most serious cases, apply counter-measures to protect the international financial system from the money laundering, terrorist financing, and proliferation financing risks emanating from the identified countries.” FinCEN’s announcement also informs members that FATF removed Malta from its list of Jurisdictions under Increased Monitoring and added Gibraltar, and that its list of High-Risk Jurisdictions Subject to a Call for Action continues to subject Iran and the Democratic People’s Republic of Korea to the FATF’s countermeasures.