In an advisory, FinCEN alerted financial institutions to recent Financial Action Task Force ("FATF") updates to the list of jurisdictions with strategic AML and combating the financing of terrorism ("AML/CFT") deficiencies. FinCEN stated that changes to the FATF list may affect U.S. financial institutions' risk-based due diligence obligations concerning the affected jurisdictions.

The FATF's "High-Risk Jurisdictions Subject to a Call for Action," published on February 21, 2020, remains in effect. As previously covered, the FATF called for (i) enhanced due diligence and countermeasures with respect to the Democratic People's Republic of Korea (or "DPRK") and (ii) enhanced due diligence and renewed countermeasures with respect to Iran.

The FATF's "Jurisdictions under Increased Monitoring," published on February 21, 2020, also remains in effect. A June 30, 2020 statement from the FATF states that while Iceland and Mongolia have "substantially completed" action plans for AML/CFT reforms, the two countries will remain on the FATF list until on-site visits are possible. The other countries remaining on the list are Albania, The Bahamas, Barbados, Botswana, Burma (Myanmar), Cambodia, Ghana, Iceland, Jamaica, Mauritius, Nicaragua, Pakistan, Panama, Syria, Uganda, Yemen and Zimbabwe.

Originally published July 15, 2020.

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