The Financial Crimes Enforcement Network has issued an advisory to make financial institutions aware of updates by the Financial Action Task Force to its list of jurisdictions with strategic deficiencies in their anti-money laundering (AML) and countering terrorist financing (CFT) regimes. FinCEN noted that while the FATF had paused its review of most countries with strategic deficiencies, as lockdowns and travel restrictions adopted by countries in response to the coronavirus pandemic have made site visits impracticable, the FATF’s February 2020 statement, “High Risk Jurisdictions Subject to a Call for Action,” remains in effect. That statement urged all jurisdictions to take measures to protect the international financial system from the AML and CFT deficiencies of Iran and the Democratic People’s Republic of Korea.
The FATF’s list of jurisdictions under increased monitoring includes Albania, the Bahamas, Barbados, Botswana, Burma (Myanmar), Cambodia, Ghana, Iceland, Jamaica, Mauritius, Mongolia, Nicaragua, Pakistan, Panama, Syria, Uganda, Yemen, and Zimbabwe; although Iceland and Mongolia had made progress toward completing their AML/CFT action plans prior to the pandemic, they will remain on the increased monitoring list until compliance can be confirmed by a site visit.
With regard to these jurisdictions, FinCEN’s advisory reminds covered institutions of their obligations to conduct due diligence consistent with the requirements of 31 CFR § 1010.610(a), including risk-based policies, procedures and controls designed to detect and report suspected money laundering activity conducted through correspondent accounts in the US. Likewise, FinCEN admonishes money services businesses of their parallel obligations under FinCEN Interpretive Release 2004-1. FinCEN also emphasized the importance of accurate Suspicious Activity Reports as a critical element in AML, CFT and sanctions investigations and enforcement.