On October 23, 2020 the Financial Action Task Force (FATF) updated its list of jurisdictions with strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing. The change may affect financial institutions’ obligations and risk-based approaches with respect to relevant jurisdictions.
In Summary:
Identified high-risk jurisdictions remain the same as the FATF’s February 2020 statement.
Identified increased monitoring jurisdictions dropped Iceland and Mongolia. Remaining on the list are: Albania, The Bahamas, Barbados, Botswana, Burma (Myanmar), Cambodia, Ghana, Jamaica, Mauritius, Nicaragua, Pakistan, Panama, Syria, Uganda, Yemen, and Zimbabwe.
When filing SARs, financial institutions should provide all pertinent available information in the SAR form and narrative. FinCEN requests that financial institutions reference this advisory by including the key term “October 2020 FATF FIN-2020-A009” in SAR field 2 (Filing Institution Note to FinCEN) and the narrative to indicate a connection between the suspicious activity being reported and the activities highlighted in this advisory.
See the FinCEN Advisory, FIN-2020-A009, Advisory on the Financial Action Task Force-Identified Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Proliferation Deficiencies for full details.
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