The Financial Intelligence Analysis Unit (the “FIAU”), issued a notice on the 2nd July 2020, referring to the Financial Action Task Force’s (the “FATF”) Public statement issued on the 30th June 2020, in relation to “High-Risk Jurisdictions subject to a Call for Action” and “Jurisdictions under Increased Monitoring”.
The FATF classifies these jurisdictions under the following categories:
- Jurisdictions that have failed to meaningfully address their Anti-Money Laundering and Countering Financing of Terrorism (“AML/CFT”) deficiencies and are subject to a call for counter-measures (“High-Risk Jurisdictions subject to a Call for Action”);
- Jurisdictions that have not made sufficient progress in addressing their AML/CFT deficiencies or have not committed to an action plan developed with the FATF (“High-Risk Jurisdictions subject to a Call for Action”);
- Jurisdictions that have developed an action plan with the FATF and have made a high-level political commitment to address their AML/CFT deficiencies (“Jurisdictions under Increased Monitoring”).
This document includes jurisdictions that are no longer subject to the FATF on-going global AML/CFT compliance process, where applicable.
High-Risk Jurisdictions subject to a Call for Action
The review process for the list of “High-Risk Jurisdictions subject to a Call for Action” was put on hold by the FATF, due to the COVID-19 situation. Subject persons should refer to the list of “High-Risk Jurisdictions subject to a Call for Action” implemented in February 2020. The FATF’s call for action in relation to the Democratic People’s Republic of Korea and Iran’s AML/CFT regime remain effective. In this regard, subject persons are requested to consult with Regulation 11(11) of the Prevention of Money Laundering and Funding of Terrorism Regulations and apply the due diligence measures set in this Regulation.
Jurisdictions under Increased Monitoring
The review process for the list of jurisdictions under increased monitoring was also put on hold by the FATF, due to the current COVID-19 situation. An additional extension of four months for deadlines have been given to jurisdictions by the FATF.
Mongolia and Iceland have continued with their original schedule, as per their request.
A high-level political commitment to work with the FATF was made in October 2019 by Iceland, in order to strengthen the efficiency of its AML/CFT regime and tackle any related technical deficiencies.
Iceland has made several crucial amendments such as ensuring the access to accurate basic and beneficial ownership information for legal persons by competent authorities in a timely manner and introducing an automated system for suspicious transaction reporting.
A high-level political commitment to work with the FATF was made in October 2019 by Mongolia, in order to strengthen the efficiency of its AML/CFT regime and tackle any related technical deficiencies.
Mongolia has, in particular, made various crucial amendments such as improving the sectoral ML/FT risk understanding by DNFBP supervisors and demonstrated increased investigations and prosecutions of different types of ML activity in line with identified risks.
The FATF is monitoring the COVID-19 situation, and an on-site visit will take place at the earliest feasible date.
Furthermore, the FATF confirmed that the following jurisdictions continue to be subject to increased monitoring; Albania, The Bahamas, Barbados, Botswana, Cambodia, Ghana, Jamaica, Mauritius, Myanmar, Nicaragua, Pakistan, Panama, Syria, Uganda, Yemen and Zimbabwe.
Further information for details concerning each jurisdiction can be found in the statement issued by the FATF in February 2020. The current status in the jurisdiction’s AML/CFT regime may not inevitably be shown in this statement.
In view of the above, subject persons should consult to Regulation 11(10) of the Prevention of Money Laundering and Funding of Terrorism Regulations, in order to apply enhanced due diligence measures to the mentioned jurisdictions.
Please do not hesitate to contact us if you require any further information in relation to AML/CFT.