The FATF identifies Jurisdictions with Strategic Deficiencies

On the 23rd November 2020, the Malta Financial Services Authority (“MFSA”) issued a circular bringing to the attention of relevant entities the publication made by the Financial Action Task Force (“FATF”) which identifies countries which currently have strategic deficiencies with regards to anti-money laundering and combatting the funding of terrorism (“ML/FT”).

The FATF’s publication consists of two separate documents which are split according to the type of jurisdictions which have deficiencies in ML/FT. The High-Risk Jurisdictions subject to a Call for Action document, dated 23rd October 2020, identifies jurisdictions with serious ML/FT deficiencies which are further categorised in the following manner:

  1. Jurisdictions to which counter measures apply; and
  2. Jurisdictions that have not made sufficient progress in addressing the deficiencies or have not committed to an action plan developed with the FATF to address the deficiencies. Additionally, the FATF calls on its members to consider the risks arising from the deficiencies associated with each jurisdiction.

On the 2nd August 2020, the FATF decided to pause the review process for the list of High-Risk Jurisdictions subject to a Call for Action and therefore the statement made by it in February 2020 still applies. The jurisdictions currently subject to a call for action are Iran and the Democratic People’s Republic of Korea.

The other document consists of Jurisdictions under Increased Monitoring, dated 23rd October 2020, which identifies jurisdictions that have provided a high-level political commitment to address their ML/FT deficiencies through the implementation of an action plan developed with the FATF.

The below list provides the jurisdictions which are currently under increased monitoring:

Jurisdictions with strategic deficiencies
Albania Zimbabwe
The Bahamas Myanmar
Barbados Nicaragua
Botswana Pakistan
Cambodia Panama
Ghana Syria
Mauritius Uganda
Jamaica Yemen


The FATF have also highlighted that the jurisdictions of Iceland and Mongolia are no longer subject to increased monitoring.

The MFSA also reminded relevant entities, that in order to satisfy their ML/FT obligations when entering into any type of business with any of the aforementioned jurisdictions, reference should be made to the measures listed in the FIAU Implementing Procedures (Part I), especially Chapter 8, section 8.1.

Feel free to send us an email should you require any further information on the obligations arising out of the FATF’s publications.