Paris, 22 October 2010 - The Financial Action Task Force (FATF) is the global standard setting body for anti-money laundering and combating
the financing of terrorism (AML/CFT). In order to protect the international financial system from ML/FT risks and to encourage greater
compliance with the AML/CFT standards, the FATF identified jurisdictions that have strategic deficiencies and, along with the FATF-style regional
bodies (FSRBs), works with them to address those deficiencies that pose a risk to the international financial system. The FATF and the relevant
FSRBs will continue to work with the jurisdictions below and report on their progress in addressing the identified deficiencies.
1. Jurisdictions subject to a FATF call on its members and other jurisdictions to apply counter-measures to protect the international financial
system from the ongoing and substantial money laundering and terrorist financing (ML/TF) risks emanating from the jurisdiction *:
Iran
2. Jurisdictions with strategic AML/CFT deficiencies that have not committed to an action plan developed with the FATF to address key
deficiencies as of October 2010. The FATF calls on its members to consider the risks arising from the deficiencies associated with the
jurisdiction, as described below.
Democratic People's Republic of Korea (DPRK)
* The FATF has previously issued public statements calling for counter-measures on Iran. Those statements are updated below.
1. Jurisdictions subject to a FATF call on its members and other jurisdictions to apply counter-measures to protect the international financial
system from the ongoing and substantial money laundering and terrorist financing (ML/TF) risks emanating from the jurisdiction:
Iran
The FATF welcomes the recent steps that Iran has taken to engage with the FATF, but remains concerned by Iran’s failure to meaningfully
address the ongoing and substantial deficiencies in its anti-money laundering and combating the financing of terrorism (AML/CFT) regime. The
FATF remains particularly concerned about Iran’s failure to address the risk of terrorist financing and the serious threat this poses to the
integrity of the international financial system. The FATF urges Iran to immediately and meaningfully address its AML/CFT deficiencies, in
particular by criminalising terrorist financing and effectively implementing suspicious transaction reporting (STR) requirements.
The FATF reaffirms its call on members and urges all jurisdictions to advise their financial institutions to give special attention to business
relationships and transactions with Iran, including Iranian companies and financial institutions. In addition to enhanced scrutiny, the FATF
reaffirms its 25 February 2009 call on its members and urges all jurisdictions to apply effective counter-measures to protect their financial
sectors from money laundering and financing of terrorism (ML/FT) risks emanating from Iran. FATF continues to urge jurisdictions to protect
against correspondent relationships being used to bypass or evade counter-measures and risk mitigation practices, and to take into account
ML/FT risks when considering requests by Iranian financial institutions to open branches and subsidiaries in their jurisdiction. If Iran fails to take
concrete steps to improve its AML/CFT regime, the FATF will consider calling on its members and urging all jurisdictions to strengthen counter-
measures in February 2011.
2. Jurisdictions with strategic AML/CFT deficiencies that have not committed to an action plan developed with the FATF to address key
deficiencies as of October 2010. The FATF calls on its members to consider the risks arising from the deficiencies associated with the
jurisdiction, as described below.
Democratic People's Republic of Korea (DPRK)
The Democratic People’s Republic of Korea (DPRK) has not committed to the AML/CFT international standards, nor has it responded to the
FATF’s numerous requests for engagement on these issues. DPRK’s lack of a comprehensive AML/CFT regime poses a risk to the international
financial system. DPRK should work with the FATF to develop a viable AML/CFT regime in line with international standards.
Part 2
Jurisdictions which have strategic AML/CFT deficiencies for which they have developed an action plan with the FATF.
Paris, 22 October 2010 - As part of its ongoing review of compliance with the AML/CFT standards, the FATF has to date identified the following
jurisdictions which have strategic AML/CFT deficiencies for which they have developed an action plan with the FATF. While the situations differ
among each jurisdiction, each jurisdiction has provided a written high-level political commitment to address the identified deficiencies. FATF
welcomes these commitments.
A large number of jurisdictions have not yet been reviewed by the FATF. The FATF continues to identify additional jurisdictions, on an ongoing
basis, that pose a risk in the international financial system. The new jurisdictions identified in this document are: Bangladesh, Ghana, Honduras,
Philippines, Tanzania, Venezuela, and Vietnam. The FATF has additionally begun initial reviews of a number of other jurisdictions as part of this
process and will present its findings next year.
The FATF and the FSRBs will continue to work with the jurisdictions noted below and to report on the progress made in addressing the identified
deficiencies. The FATF calls on these jurisdictions to complete the implementation of action plans expeditiously and within the proposed
timeframes. The FATF will closely monitor the implementation of these action plans and encourages its members to consider the information
presented below.
Angola
In June 2010, Angola made a high-level political commitment to work with the FATF to address its strategic AML/CFT deficiencies. Since June,
Angola has taken steps towards improving its AML/CFT regime, including by enacting an AML/CFT law and ratifying the UN Convention on
Transnational Organised Crime. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Angola will work on
implementing its action plan to address these deficiencies, including by: (1) adequately criminalising money laundering and terrorist financing
(Recommendation 1 and Special Recommendation II); (2) establishing a fully operational and effectively functioning Financial Intelligence Unit
(Recommendation 26); (3) establishing and implementing an adequate legal framework for identifying, tracing and freezing terrorist assets
(Special Recommendation III); and (4) ratifying the UN Convention for the Suppression of the Financing of Terrorism. The FATF encourages
Angola to address its remaining deficiencies and continue the process of implementing its action plan.
Antigua and Barbuda
In February 2010, Antigua and Barbuda made a high-level political commitment to work with the FATF and CFATF to address its strategic
AML/CFT deficiencies. Since June, Antigua and Barbuda has taken steps towards improving its AML/CFT regime, including by passing the
Cooperative Societies Bill framework. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Antigua and
Barbuda should continue to work on implementing its action plan to address these deficiencies, including by: (1) implementing an adequate
legal framework for identifying and freezing terrorist assets (Special Recommendation III); (2) continuing to improve the overall supervisory
framework (Recommendation 23); and (3) enhancing financial transparency (Recommendation 4). The FATF encourages Antigua and Barbuda
to address its remaining deficiencies and continue the process of implementing its action plan.
Bangladesh
In October 2010, Bangladesh made a high-level political commitment to work with the FATF and APG to address its strategic AML/CFT
deficiencies. Bangladesh has taken steps towards improving its AML/CFT regime. However, the FATF has determined that certain strategic
AML/CFT deficiencies remain. Bangladesh will work on implementing its action plan to address these deficiencies, including by: (1) adequately
criminalising money laundering and terrorist financing (Recommendation 1 and Special Recommendation II); (2) establishing and implementing
adequate procedures to identify and freeze terrorist assets (Special Recommendation III); (3) implementing adequate procedures for the
confiscation of funds related to money laundering (Recommendation 3); (4) ensuring a fully operational and effectively functioning Financial
Intelligence Unit (Recommendation 26); (5) improving suspicious transaction reporting requirements (Recommendation 13 and Special
Recommendation IV); and (6) improving international cooperation (Recommendations 36 and 39 and Special Recommendation V). The FATF
encourages Bangladesh to address its remaining deficiencies and continue the process of implementing its action plan.
Bolivia
In February 2010, Bolivia made a high-level political commitment to work with the FATF and GAFISUD to address its strategic AML/CFT
deficiencies. However, the FATF has determined that certain strategic deficiencies remain. Bolivia should continue to work on implementing its
action plan to address these deficiencies, including by: (1) ensuring adequate criminalisation of money laundering g (Recommendation 1); (2)
adequately criminalizing terrorist financing (Special Recommendation II); (3) establishing and implementing an adequate legal framework for
identifying and freezing terrorist assets (Special Recommendation III); and (4) establishing a fully operational and effective Financial Intelligence
Unit (Recommendation 26). The FATF encourages Bolivia to address its remaining deficiencies and continue the process of implementing its
action plan.
Ecuador
In June 2010, Ecuador made a high-level political commitment to work with the FATF and GAFISUD to address its strategic AML/CFT
deficiencies. Since June, Ecuador has taken steps towards improving its AML/CFT regime, including by tabling a revised AML/CFT law. However,
the FATF has determined that certain strategic AML/CFT deficiencies remain. Ecuador will work on implementing its action plan to address these
deficiencies, including by: (1) adequately criminalising money laundering and terrorist financing (Recommendation 1 and Special
Recommendation II); (2) establishing and implementing adequate procedures to identify and freeze terrorist assets (Special Recommendation
III); (3) implementing adequate procedures for the confiscation of funds related to money laundering (Recommendation 3); and (4) reinforcing
and improving coordination of financial sector supervision (Recommendation 23). The FATF encourages Ecuador to address its remaining
deficiencies and continue the process of implementing its action plan.
Ethiopia
In June 2010, Ethiopia made a high-level political commitment to work with the FATF to address its strategic AML/CFT deficiencies. However, the
FATF has determined that certain strategic AML/CFT deficiencies remain. Ethiopia will work on implementing its action plan to address these
deficiencies, including by: (1) adequately criminalising money laundering and terrorist financing (Recommendation 1 and Special
Recommendation II); (2) establishing and implementing an adequate legal framework and procedures to identify and freeze terrorist assets
(Special Recommendation III); (3) ensuring a fully operational and effectively functioning Financial Intelligence Unit (Recommendation 26); (4)
raising awareness of AML/CFT issues within the law enforcement community (Recommendation 27); and (5) implementing effective,
proportionate and dissuasive sanctions in order to deal with natural or legal persons that do not comply with the national AML/CFT requirements
(Recommendation 17). The FATF encourages Ethiopia to address its remaining deficiencies and continue the process of implementing its action
plan.
Ghana
In October 2010, Ghana made a high-level political commitment to work with the FATF and GIABA to address its strategic AML/CFT deficiencies.
Ghana has taken steps towards improving its AML/CFT regime. However, the FATF has determined that strategic AML/CFT deficiencies remain.
Ghana will work on implementing its action plan to address these deficiencies, including by: (1) adequately criminalising money laundering and
terrorist financing (Recommendation 1 and Special Recommendation II); (2) establishing and implementing adequate measures for the
confiscation of funds related to money laundering (Recommendation 3); (3) establishing effective CDD measures (Recommendation 5); (4)
establishing a fully operational and effectively functioning Financial Intelligence Unit (Recommendation 26); and (5) establishing and
implementing adequate procedures to identify and freeze terrorist assets (Special Recommendation III). The FATF encourages Ghana to
address its remaining deficiencies and continue the process of implementing its action plan.
Greece
In February 2010, Greece made a high-level political commitment to work with the FATF to address its strategic AML/CFT deficiencies. Since
June, Greece has taken steps towards improving its AML/CFT regime, including by taking measures to enhance the effectiveness of the FIU and
adopting legislation to adequately criminalise terrorist financing. However, the FATF has determined that certain strategic AML/CFT deficiencies
remain. Greece should continue to work on implementing its action plan to address these deficiencies, including by: (1) improving exisiting
mechanisms and procedures for freezing terrorist assets under UNSCR 1373 (Special Recommendation III); and (2) further enhancing the
effectiveness of the FIU (Recommendation 26). The FATF encourages Greece to address its remaining deficiencies and continue the process of
implementing its action plan.
Honduras
In October 2010, Honduras made a high-level political commitment to work with the FATF and CFATF to address its strategic AML/CFT
deficiencies. Honduras has taken steps towards improving its AML/CFT regime. However, the FATF has determined that strategic AML/CFT
deficiencies remain. Honduras will work on implementing its action plan to address these deficiencies, including by: (1) adequately criminalising
terrorist financing (Special Recommendation II); (2) establishing and implementing adequate procedures to identify and freeze terrorist assets
(Special Recommendation III); (3) ensuring a fully operational and effectively functioning Financial Intelligence Unit (Recommendation 26); and
(4) improving and broadening CDD measures (Recommendation 5). The FATF encourages Honduras to address its remaining deficiencies and
continue the process of implementing its action plan.
Indonesia
In February 2010, Indonesia made a high-level political commitment to work with the FATF and the APG to address its strategic AML/CFT
deficiencies. Since June, Indonesia has taken steps towards improving its AML/CFT regime, including by approving a new AML law on October
2010. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Indonesia should continue to work on
implementing its action plan to address these deficiencies, including by: (1) adequately criminalising terrorist financing (Special
Recommendation II); (2) ensuring effective criminalisation of money laundering (Recommendation 1); (2) establishing and implementing
adequate procedures to identify and freeze terrorist assets (Special Recommendation III); and (3) amending and implementing laws or other
instruments to fully implementing the 1999 International Convention for the Suppression of Financing of Terrorism (Special Recommendation I).
The FATF encourages Indonesia to address its remaining deficiencies and continue the process of implementing its action plan.
Kenya
In February 2010, Kenya made a high-level political commitment to work with the FATF and ESAAMLG to address its strategic AML/CFT
deficiencies. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Kenya should continue to work on
implementing its action plan to address these deficiencies, including by: (1) adequately criminalising terrorist financing (Special
Recommendation II); (2) ensuring a fully operational and effectively functioning Financial Intelligence Unit (Recommendation 26); (3)
establishing and implementing an adequate legal framework for identifying and freezing terrorist assets (Special Recommendation III); (4) raising
awareness of AML/CFT issues within the law enforcement community (Recommendation 27); and (5) implementing effective, proportionate and
dissuasive sanctions in order to deal with natural or legal persons that do not comply with the national AML/CFT requirements (Recommendation
17). The FATF encourages Kenya to address its remaining deficiencies and continue the process of implementing its action plan.
Morocco
In February 2010, Morocco made a high-level political commitment to work with the FATF and MENAFATF to address its strategic AML/CFT
deficiencies. Since June, Morocco has taken steps towards improving its AML/CFT regime, including by taking initial steps to make the FIU more
operational. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Morocco should continue to work on
implementing its action plan to address these deficiencies, including by: (1) amending the penal code to extend the scope of the ML and FT
offences (Recommendation 1 and Special Recommendation II); (2) amending relevant laws or regulations to address deficiencies in customer
due diligence requirements (Recommendation 5); and (3) ensuring a fully operational and effectively functioning Financial Intelligence Unit
(Recommendation 26). The FATF encourages Morocco to address its remaining deficiencies and continue the process of implementing its
action plan.
Myanmar
In February 2010, Myanmar made a high-level political commitment to work with the FATF and APG to address its strategic AML/CFT
deficiencies. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Myanmar should continue to work on
implementing its action plan to address these deficiencies, including by: (1) adequately criminalising money laundering and terrorist financing
(Recommendation 1 and Special Recommendation II); (2) establishing and implementing adequate procedures to identify and freeze terrorist
assets (Special Recommendation III); (3) strengthening the extradition framework in relation to terrorist financing (Recommendation 35 and
Special Recommendation I); (4) ensuring a fully operational and effectively functioning Financial Intelligence Unit (Recommendation 26); (5)
enhancing financial transparency (Recommendation 4); and (6) strengthening customer due diligence measures (Recommendations 5). The
FATF encourages Myanmar to address its remaining deficiencies and continue the process of implementing its action plan.
Nepal
In February 2010, Nepal made a high-level political commitment to work with the FATF and APG to address its strategic AML/CFT deficiencies.
Since June, Nepal has taken steps towards improving its AML/CFT regime, including by tabling draft amendments on money laundering and
terrorist financing. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Nepal should continue to work on
implementing its action plan to address these deficiencies, including by: (1) adequately criminalising money laundering and terrorist financing
(Recommendation 1 and Special Recommendation II); (2) establishing and implementing adequate procedures to identify and freeze terrorist
assets (Special Recommendation III); (3) implementing adequate procedures for the confiscation of funds related to money laundering
(Recommendation 3); and (4) enacting and implementing appropriate mutual legal assistance legislation (Recommendation 36). The FATF
encourages Nepal to address its remaining deficiencies and continue the process of implementing its action plan.
Nigeria
In February 2010, Nigeria made a high-level political commitment to work with the FATF and GIABA to address its strategic AML/CFT
deficiencies. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Nigeria should continue to work on
implementing its action plan to address these deficiencies, including by: (1) adequately criminalising money laundering and terrorist financing
(Recommendation 1 and Special Recommendation II); (2) implementing adequate procedures to identify and freeze terrorist assets (Special
Recommendation III); (3) ensuring that relevant laws or regulations address deficiencies in customer due diligence requirements and that they
apply to all financial institutions (Recommendation 5); and (4) demonstrating that AML/CFT supervision is undertaken effectively across the
financial sector (Recommendation 23). The FATF encourages Nigeria to address its remaining deficiencies and continue the process of
implementing its action plan.
Pakistan
In June 2010, Pakistan made a high-level political commitment to work with the FATF and APG to address its strategic AML/CFT deficiencies.
Since June, Pakistan has taken steps towards improving its AML/CFT regime, including by broadening the scope of ML predicate offences.
However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Pakistan will work on implementing its action plan to
address these deficiencies, including by (1) demonstrating adequate criminalisation of money laundering and terrorist financing
(Recommendation 1 and Special Recommendation II); (2) demonstrating adequate procedures to identify, freeze and confiscate terrorist assets
(Special Recommendation III); (3) ensuring a fully operational and effectively functioning Financial Intelligence Unit (Recommendation 26); (4)
demonstrating effective regulation of money service providers, including an appropriate sanctions regime, and increasing the range of ML/FT
preventive measures for these services (Special Recommendation VI); and (5) improving and implementing effective controls for cross-border
cash transactions (Special Recommendation IX). The FATF encourages Pakistan to address its remaining deficiencies and continue the process
of implementing its action plan.
Paraguay
In February 2010, Paraguay made a high-level political commitment to work with the FATF and GAFISUD to address its strategic AML/CFT
deficiencies. Since June, Paraguay has taken steps towards improving its AML/CFT regime, including by establishing some fundamental CDD
measures. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Paraguay should continue to work on
implementing its action plan to address these deficiencies, including by: (1) establishing and implementing adequate procedures to identify,
freeze and confiscate terrorist assets (Special Recommendation III); (2) improving financial transparency (Recommendation 4); (3) improving
and broadening customer due diligence measures (Recommendation 5); and (4) implementing effective controls for cross-border cash
transactions (Special Recommendation IX). The FATF encourages Paraguay to address its remaining deficiencies and continue the process of
implementing its action plan.
Philippines
In October 2010, the Philippines made a high-level political commitment to work with the FATF and APG to address its strategic AML/CFT
deficiencies. The Philippines has taken steps towards improving its AML/CFT regime. However, the FATF has determined that certain strategic
AML/CFT deficiencies remain. The Philippines will work on implementing its action plan to address these deficiencies, including by: (1)
adequately criminalising money laundering and terrorist financing (Recommendation 1 and Special Recommendation II); (2) implementing
adequate procedures to identify and freeze terrorist assets and confiscate funds related to money laundering (Special Recommendation III and
Recommendation 3); (3) enhancing financial transparency (Recommendation 4); (4) ensuring capacity and financial resources for competent
authorities (Recommendation 30); and (5) establishing effective CDD measures (Recommendation 5). The FATF encourages the Philippines to
address its remaining deficiencies and continue the process of implementing its action plan.
São Tomé and Príncipe
In October 2010, São Tomé and Príncipe made a high-level political commitment to work with the FATF and GIABA to address its strategic
AML/CFT deficiencies. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. São Tomé and Príncipe will work
on implementing its action plan to address these deficiencies, including by: (1) adequately criminalising money laundering and terrorist financing
(Recommendation 1 and Special Recommendation II); (2) establishing a fully operational and effectively functioning Financial Intelligence Unit
(Recommendation 26); (3) ensuring that financial institutions and DNFBPs are subject to adequate AML/CFT regulation and supervision, and
that competent authority or authorities have been designated to ensure compliance with AML/CFT requirements (Recommendations 23, 24 and
29); (4) implementing effective, proportionate and dissuasive sanctions in order to deal with natural or legal persons that do not comply with the
national AML/CFT requirements (Recommendation 17); and (5) taking the necessary action to gain membership of GIABA. The FATF
encourages São Tomé and Príncipe to address its remaining deficiencies and continue the process of implementing its action plan.
Sri Lanka
In February 2010, Sri Lanka made a high-level political commitment to work with the FATF and APG to address its strategic AML/CFT
deficiencies. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Sri Lanka should continue to work on
implementing its action plan to address these deficiencies, including by: (1) adequately criminalising money laundering and terrorist financing
(Recommendation 1 and Special Recommendation II); and (2) establishing and implementing adequate procedures to identify and freeze
terrorist assets (Special Recommendation III). The FATF encourages Sri Lanka to address its remaining deficiencies and continue the process
of implementing its action plan.
Sudan
In February 2010, Sudan made a high-level political commitment to work with the FATF and MENAFATF to address its strategic AML/CFT
deficiencies. Since June, Sudan has taken steps towards improving its AML/CFT regime, including by conducting outreach to financial
institutions on AML/CFT obligations and taking initial steps to operationalise the FIU. However, the FATF has determined that certain strategic
AML/CFT deficiencies remain. Sudan should continue to work on implementing its action plan to address these deficiencies, including by: (1)
implementing adequate procedures for identifying and freezing terrorist assets (Special Recommendation III); (2) ensuring a fully operational
and effectively functioning Financial Intelligence Unit (Recommendation 26); (3) ensuring financial institutions are aware of and comply with their
obligations to file suspicious transaction reports in relation to ML and FT (Recommendation 13 and Special Recommendation IV); and (4)
implementing a supervisory programme for the regulators to ensure compliance with the provisions of the new law and regulations
(Recommendation 23). The FATF encourages Sudan to address its remaining deficiencies and continue the process of implementing its action
plan.
Syria
In February 2010, Syria made a high-level political commitment to work with the FATF and MENAFATF to address its strategic AML/CFT
deficiencies. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Syria should continue to work on
implementing its action plan to address these deficiencies, including by: (1) adopting adequate measures to implement and enforce the 1999
International Convention for the Suppression of Financing of Terrorism (Special Recommendation I); (2) adequately criminalising terrorist
financing (Special Recommendation II); (3) implementing adequate procedures for identifying and freezing terrorist assets (Special
Recommendation III); (4) ensuring financial institutions are aware of and comply with their obligations to file suspicious transaction reports in
relation to ML and FT (Recommendation 13 and Special Recommendation IV) and (5) adopting appropriate laws and procedures to provide
mutual legal assistance (Recommendations 36-38, Special Recommendation V). The FATF encourages Syria to address its remaining
deficiencies and continue the process of implementing its action plan.
Tanzania
In October 2010, Tanzania made a high-level political commitment to work with the FATF and ESAAMLG to address its strategic AML/CFT
deficiencies. Tanzania has taken steps towards improving its AML/CFT regime. However, the FATF has determined that certain strategic
AML/CFT deficiencies remain. Tanzania will work on implementing its action plan to address these deficiencies, including by: (1) adequately
criminalising money laundering and terrorist financing (Recommendation 1 and Special Recommendation II); (2) establishing and implementing
adequate procedures to identify and freeze terrorist assets as well as implementing the UNSCR 1267 and 1373 through law, regulations or
other enforceable means (Special Recommendation III); (3) establishing effective CDD measures (Recommendation 5); (4) establishing
adequate record-keeping requirements (Recommendation 10); (5) establishing a fully operational and effectively functioning national Financial
Intelligence Unit (Recommendation 26); and (6) designating competent authorities to ensure compliance with AML/CFT requirements
(Recommendation 23). The FATF encourages Tanzania to address its remaining deficiencies and continue the process of implementing its
action plan.
Thailand
In February 2010, Thailand made a high-level political commitment to work with the FATF and APG to address its strategic AML/CFT
deficiencies. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Thailand should continue to work on
implementing its action plan to address these deficiencies, including by: (1) adequately criminalising terrorist financing (Special
Recommendation II); (2) establishing and implementing adequate procedures to identify and freeze terrorist assets (Special Recommendation
III); and (3) further strengthening AML/CFT supervision (Recommendation 23). The FATF encourages Thailand to address its remaining
deficiencies and continue the process of implementing its action plan.
Trinidad and Tobago
In February 2010, Trinidad and Tobago made a high-level political commitment to work with the FATF and CFATF to address its strategic
AML/CFT deficiencies. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Trinidad and Tobago should
continue to work on implementing its action plan to address these deficiencies, including by: (1) implementing adequate procedures to identify
and freeze terrorist assets without delay (Special Recommendation III); (2) implementing adequate procedures for the confiscation of funds
related to money laundering (Recommendation 3); and (3) establishing a fully operational and effectively functioning FIU, including supervisory
powers (Recommendation 26). The FATF encourages Trinidad and Tobago to address its remaining deficiencies and continue the process of
implementing its action plan.
Turkey
In February 2010, Turkey made a high-level political commitment to work with the FATF to address its strategic AML/CFT deficiencies. Since
June, Turkey has taken steps towards improving its AML/CFT regime, including by working on draft CFT legislation. However, the FATF has
determined that certain strategic AML/CFT deficiencies remain. Turkey should continue to work on implementing its action plan to address these
deficiencies, including by: (1) adequately criminalising terrorist financing (Special Recommendation II); and (2) implementing an adequate legal
framework for identifying and freezing terrorist assets (Special Recommendation III). The FATF encourages Turkey to address its remaining
deficiencies and continue the process of implementing its action plan.
Turkmenistan
In June 2010, Turkmenistan made a high-level political commitment to work with the FATF and EAG to address its strategic AML/CFT
deficiencies. Since June, Turkmenistan has taken steps towards improving its AML/CFT regime, including by holding training workshops to build
the capacity of its FIU. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Turkmenistan will work on
implementing its action plan to address these deficiencies, including by: (1) addressing the remaining issues with the criminalisation of money
laundering and terrorist financing (Recommendation 1 and Special Recommendation II), (2) implementing adequate procedures to identify and
freeze terrorist assets without delay (Special Recommendation III); (3) ensuring a fully operational and effectively functioning FIU
(Recommendation 26), (4) developing collaboration between the FIU and domestic counterparts, including supervisory authorities, and (5)
strengthening international cooperation. The FATF encourages Turkmenistan to address its remaining deficiencies and continue the process of
implementing its action plan.
Ukraine
In February 2010, Ukraine made a high-level political commitment to work with the FATF and MONEYVAL to address its strategic AML/CFT
deficiencies. Since June, Ukraine has taken steps towards improving its AML/CFT regime, including by bringing a new AML/CFT law into force.
However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Ukraine should continue to work on implementing its
action plan to address these deficiencies, including by: (1) addressing remaining issues regarding criminalisation of money laundering
(Recommendation 1); and (2) improving and implementing an adequate legal framework for identifying and freezing terrorist assets (Special
Recommendation III). The FATF encourages Ukraine to address its remaining deficiencies and continue the process of implementing its action
plan.
Venezuela
In October 2010, Venezuela made a high-level political commitment to work with the FATF and CFATF to address its strategic AML/CFT
deficiencies. Venezuela has taken steps towards improving its AML/CFT regime. However, the FATF has determined that certain strategic
deficiencies remain. Venezuela will work with the FATF and CFATF on implementing its action plan to address these deficiencies, including by:
(1) adequately criminalising terrorist financing (Special Recommendation II); (2) establishing and implementing adequate procedures to identify
and freeze terrorist assets (Special Recommendation III); (3) ensuring a fully operational and effectively functioning Financial Intelligence Unit
(Recommendation 26); (4) implementing adequate CDD guidelines for all sectors (Recommendation 5); and (5) establishing adequate STR
reporting obligations for ML and TF (Recommendation 13 and Special Recommendation IV). The FATF encourages Venezuela to address its
remaining deficiencies and continue the process of implementing its action plan.
Vietnam
In October 2010, Vietnam made a high-level political commitment to work with the FATF to address its strategic AML/CFT deficiencies. Vietnam
has taken steps towards improving its AML/CFT regime. However, the FATF has determined that certain strategic AML/CFT deficiencies remain.
Vietnam will work with the FATF and the APG on implementing its action plan to address these deficiencies, including by: (1) adequately
criminalising money laundering and terrorist financing (Recommendation 1 and Special Recommendation II); (2) establishing and implementing
adequate procedures to identify and freeze terrorist assets (Special Recommendation III); (3) improving the overall supervisory framework
(Recommendation 23); (4) improving and broadening customer due diligence measures and reporting requirements (Recommendation 5, 13,
and Special Recommendation IV); and (5) strengthening international cooperation (Recommendations 36, 40). The FATF encourages Vietnam
to address its remaining deficiencies and continue the process of implementing its action plan.
Yemen
In February 2010, Yemen made a high-level political commitment to work with the FATF and MENFATF to address its strategic AML/CFT
deficiencies. However, the FATF has determined that certain strategic deficiencies remain. Yemen should continue to work on implementing its
action plan to address these deficiencies, including by: (1) issue regulations to implement AML law; (2) establishing and implementing adequate
procedures to identify and freeze terrorist assets (Special Recommendation III); (3) issuing substantive guidance/instructions to reporting
institutions with respect to their ML/FT obligations (Recommendation 25); (4) developing the monitoring and supervisory capacity of the financial
sector supervisory authorities and the FIU, to ensure compliance by financial institutions with their STR obligations, especially in relation to FT
(Recommendation 23); and (5) ensuring a fully operational and effectively functioning Financial Intelligence Unit (Recommendation 26). The
FATF encourages Yemen to address its remaining deficiencies and continue the process of implementing its action plan.
In February 2010, the FATF identified the following jurisdictions as having strategic AML/CFT deficiencies. Since then, they have substantially
addressed the strategic deficiencies identified in their action plans and will be removed from this FATF monitoring process. The jurisdictions will
continue to work with their respective FSRBs to improve their AML/CFT regimes.
Qatar
The FATF welcomes Qatar’s significant progress in improving its AML/CFT regime and notes that Qatar has met its commitments in its Action
Plan regarding the strategic AML/CFT deficiencies that the FATF had identified in February 2010. Qatar is therefore no longer subject to FATF’s
monitoring process under its ongoing global AML/CFT compliance process. Qatar will work with MENAFATF as it continues to address the full
range of AML/CFT issues identified in its Mutual Evaluation Report, in particular compliance with Special Recommendation III (adequate
procedures to identify and freeze terrorist assets).
Azerbaijan
The FATF welcomes Azerbaijan’s significant progress in improving its AML/CFT regime and notes that Azerbaijan has met its commitments in its
Action Plan regarding the strategic AML/CFT deficiencies that the FATF had identified in February 2010. Azerbaijan is therefore no longer
subject to FATF’s monitoring process under its ongoing global AML/CFT compliance process. Azerbaijan will work with MONEYVAL as it
continues to address the full range of AML/CFT issues identified in its Mutual Evaluation Report, particularly compliance with SRIII (adequate
procedures to identify and freeze terrorist assets).
the financing of terrorism (AML/CFT). In order to protect the international financial system from ML/FT risks and to encourage greater
compliance with the AML/CFT standards, the FATF identified jurisdictions that have strategic deficiencies and, along with the FATF-style regional
bodies (FSRBs), works with them to address those deficiencies that pose a risk to the international financial system. The FATF and the relevant
FSRBs will continue to work with the jurisdictions below and report on their progress in addressing the identified deficiencies.
1. Jurisdictions subject to a FATF call on its members and other jurisdictions to apply counter-measures to protect the international financial
system from the ongoing and substantial money laundering and terrorist financing (ML/TF) risks emanating from the jurisdiction *:
Iran
2. Jurisdictions with strategic AML/CFT deficiencies that have not committed to an action plan developed with the FATF to address key
deficiencies as of October 2010. The FATF calls on its members to consider the risks arising from the deficiencies associated with the
jurisdiction, as described below.
Democratic People's Republic of Korea (DPRK)
* The FATF has previously issued public statements calling for counter-measures on Iran. Those statements are updated below.
1. Jurisdictions subject to a FATF call on its members and other jurisdictions to apply counter-measures to protect the international financial
system from the ongoing and substantial money laundering and terrorist financing (ML/TF) risks emanating from the jurisdiction:
Iran
The FATF welcomes the recent steps that Iran has taken to engage with the FATF, but remains concerned by Iran’s failure to meaningfully
address the ongoing and substantial deficiencies in its anti-money laundering and combating the financing of terrorism (AML/CFT) regime. The
FATF remains particularly concerned about Iran’s failure to address the risk of terrorist financing and the serious threat this poses to the
integrity of the international financial system. The FATF urges Iran to immediately and meaningfully address its AML/CFT deficiencies, in
particular by criminalising terrorist financing and effectively implementing suspicious transaction reporting (STR) requirements.
The FATF reaffirms its call on members and urges all jurisdictions to advise their financial institutions to give special attention to business
relationships and transactions with Iran, including Iranian companies and financial institutions. In addition to enhanced scrutiny, the FATF
reaffirms its 25 February 2009 call on its members and urges all jurisdictions to apply effective counter-measures to protect their financial
sectors from money laundering and financing of terrorism (ML/FT) risks emanating from Iran. FATF continues to urge jurisdictions to protect
against correspondent relationships being used to bypass or evade counter-measures and risk mitigation practices, and to take into account
ML/FT risks when considering requests by Iranian financial institutions to open branches and subsidiaries in their jurisdiction. If Iran fails to take
concrete steps to improve its AML/CFT regime, the FATF will consider calling on its members and urging all jurisdictions to strengthen counter-
measures in February 2011.
2. Jurisdictions with strategic AML/CFT deficiencies that have not committed to an action plan developed with the FATF to address key
deficiencies as of October 2010. The FATF calls on its members to consider the risks arising from the deficiencies associated with the
jurisdiction, as described below.
Democratic People's Republic of Korea (DPRK)
The Democratic People’s Republic of Korea (DPRK) has not committed to the AML/CFT international standards, nor has it responded to the
FATF’s numerous requests for engagement on these issues. DPRK’s lack of a comprehensive AML/CFT regime poses a risk to the international
financial system. DPRK should work with the FATF to develop a viable AML/CFT regime in line with international standards.
Part 2
Jurisdictions which have strategic AML/CFT deficiencies for which they have developed an action plan with the FATF.
Paris, 22 October 2010 - As part of its ongoing review of compliance with the AML/CFT standards, the FATF has to date identified the following
jurisdictions which have strategic AML/CFT deficiencies for which they have developed an action plan with the FATF. While the situations differ
among each jurisdiction, each jurisdiction has provided a written high-level political commitment to address the identified deficiencies. FATF
welcomes these commitments.
A large number of jurisdictions have not yet been reviewed by the FATF. The FATF continues to identify additional jurisdictions, on an ongoing
basis, that pose a risk in the international financial system. The new jurisdictions identified in this document are: Bangladesh, Ghana, Honduras,
Philippines, Tanzania, Venezuela, and Vietnam. The FATF has additionally begun initial reviews of a number of other jurisdictions as part of this
process and will present its findings next year.
The FATF and the FSRBs will continue to work with the jurisdictions noted below and to report on the progress made in addressing the identified
deficiencies. The FATF calls on these jurisdictions to complete the implementation of action plans expeditiously and within the proposed
timeframes. The FATF will closely monitor the implementation of these action plans and encourages its members to consider the information
presented below.
Angola
In June 2010, Angola made a high-level political commitment to work with the FATF to address its strategic AML/CFT deficiencies. Since June,
Angola has taken steps towards improving its AML/CFT regime, including by enacting an AML/CFT law and ratifying the UN Convention on
Transnational Organised Crime. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Angola will work on
implementing its action plan to address these deficiencies, including by: (1) adequately criminalising money laundering and terrorist financing
(Recommendation 1 and Special Recommendation II); (2) establishing a fully operational and effectively functioning Financial Intelligence Unit
(Recommendation 26); (3) establishing and implementing an adequate legal framework for identifying, tracing and freezing terrorist assets
(Special Recommendation III); and (4) ratifying the UN Convention for the Suppression of the Financing of Terrorism. The FATF encourages
Angola to address its remaining deficiencies and continue the process of implementing its action plan.
Antigua and Barbuda
In February 2010, Antigua and Barbuda made a high-level political commitment to work with the FATF and CFATF to address its strategic
AML/CFT deficiencies. Since June, Antigua and Barbuda has taken steps towards improving its AML/CFT regime, including by passing the
Cooperative Societies Bill framework. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Antigua and
Barbuda should continue to work on implementing its action plan to address these deficiencies, including by: (1) implementing an adequate
legal framework for identifying and freezing terrorist assets (Special Recommendation III); (2) continuing to improve the overall supervisory
framework (Recommendation 23); and (3) enhancing financial transparency (Recommendation 4). The FATF encourages Antigua and Barbuda
to address its remaining deficiencies and continue the process of implementing its action plan.
Bangladesh
In October 2010, Bangladesh made a high-level political commitment to work with the FATF and APG to address its strategic AML/CFT
deficiencies. Bangladesh has taken steps towards improving its AML/CFT regime. However, the FATF has determined that certain strategic
AML/CFT deficiencies remain. Bangladesh will work on implementing its action plan to address these deficiencies, including by: (1) adequately
criminalising money laundering and terrorist financing (Recommendation 1 and Special Recommendation II); (2) establishing and implementing
adequate procedures to identify and freeze terrorist assets (Special Recommendation III); (3) implementing adequate procedures for the
confiscation of funds related to money laundering (Recommendation 3); (4) ensuring a fully operational and effectively functioning Financial
Intelligence Unit (Recommendation 26); (5) improving suspicious transaction reporting requirements (Recommendation 13 and Special
Recommendation IV); and (6) improving international cooperation (Recommendations 36 and 39 and Special Recommendation V). The FATF
encourages Bangladesh to address its remaining deficiencies and continue the process of implementing its action plan.
Bolivia
In February 2010, Bolivia made a high-level political commitment to work with the FATF and GAFISUD to address its strategic AML/CFT
deficiencies. However, the FATF has determined that certain strategic deficiencies remain. Bolivia should continue to work on implementing its
action plan to address these deficiencies, including by: (1) ensuring adequate criminalisation of money laundering g (Recommendation 1); (2)
adequately criminalizing terrorist financing (Special Recommendation II); (3) establishing and implementing an adequate legal framework for
identifying and freezing terrorist assets (Special Recommendation III); and (4) establishing a fully operational and effective Financial Intelligence
Unit (Recommendation 26). The FATF encourages Bolivia to address its remaining deficiencies and continue the process of implementing its
action plan.
Ecuador
In June 2010, Ecuador made a high-level political commitment to work with the FATF and GAFISUD to address its strategic AML/CFT
deficiencies. Since June, Ecuador has taken steps towards improving its AML/CFT regime, including by tabling a revised AML/CFT law. However,
the FATF has determined that certain strategic AML/CFT deficiencies remain. Ecuador will work on implementing its action plan to address these
deficiencies, including by: (1) adequately criminalising money laundering and terrorist financing (Recommendation 1 and Special
Recommendation II); (2) establishing and implementing adequate procedures to identify and freeze terrorist assets (Special Recommendation
III); (3) implementing adequate procedures for the confiscation of funds related to money laundering (Recommendation 3); and (4) reinforcing
and improving coordination of financial sector supervision (Recommendation 23). The FATF encourages Ecuador to address its remaining
deficiencies and continue the process of implementing its action plan.
Ethiopia
In June 2010, Ethiopia made a high-level political commitment to work with the FATF to address its strategic AML/CFT deficiencies. However, the
FATF has determined that certain strategic AML/CFT deficiencies remain. Ethiopia will work on implementing its action plan to address these
deficiencies, including by: (1) adequately criminalising money laundering and terrorist financing (Recommendation 1 and Special
Recommendation II); (2) establishing and implementing an adequate legal framework and procedures to identify and freeze terrorist assets
(Special Recommendation III); (3) ensuring a fully operational and effectively functioning Financial Intelligence Unit (Recommendation 26); (4)
raising awareness of AML/CFT issues within the law enforcement community (Recommendation 27); and (5) implementing effective,
proportionate and dissuasive sanctions in order to deal with natural or legal persons that do not comply with the national AML/CFT requirements
(Recommendation 17). The FATF encourages Ethiopia to address its remaining deficiencies and continue the process of implementing its action
plan.
Ghana
In October 2010, Ghana made a high-level political commitment to work with the FATF and GIABA to address its strategic AML/CFT deficiencies.
Ghana has taken steps towards improving its AML/CFT regime. However, the FATF has determined that strategic AML/CFT deficiencies remain.
Ghana will work on implementing its action plan to address these deficiencies, including by: (1) adequately criminalising money laundering and
terrorist financing (Recommendation 1 and Special Recommendation II); (2) establishing and implementing adequate measures for the
confiscation of funds related to money laundering (Recommendation 3); (3) establishing effective CDD measures (Recommendation 5); (4)
establishing a fully operational and effectively functioning Financial Intelligence Unit (Recommendation 26); and (5) establishing and
implementing adequate procedures to identify and freeze terrorist assets (Special Recommendation III). The FATF encourages Ghana to
address its remaining deficiencies and continue the process of implementing its action plan.
Greece
In February 2010, Greece made a high-level political commitment to work with the FATF to address its strategic AML/CFT deficiencies. Since
June, Greece has taken steps towards improving its AML/CFT regime, including by taking measures to enhance the effectiveness of the FIU and
adopting legislation to adequately criminalise terrorist financing. However, the FATF has determined that certain strategic AML/CFT deficiencies
remain. Greece should continue to work on implementing its action plan to address these deficiencies, including by: (1) improving exisiting
mechanisms and procedures for freezing terrorist assets under UNSCR 1373 (Special Recommendation III); and (2) further enhancing the
effectiveness of the FIU (Recommendation 26). The FATF encourages Greece to address its remaining deficiencies and continue the process of
implementing its action plan.
Honduras
In October 2010, Honduras made a high-level political commitment to work with the FATF and CFATF to address its strategic AML/CFT
deficiencies. Honduras has taken steps towards improving its AML/CFT regime. However, the FATF has determined that strategic AML/CFT
deficiencies remain. Honduras will work on implementing its action plan to address these deficiencies, including by: (1) adequately criminalising
terrorist financing (Special Recommendation II); (2) establishing and implementing adequate procedures to identify and freeze terrorist assets
(Special Recommendation III); (3) ensuring a fully operational and effectively functioning Financial Intelligence Unit (Recommendation 26); and
(4) improving and broadening CDD measures (Recommendation 5). The FATF encourages Honduras to address its remaining deficiencies and
continue the process of implementing its action plan.
Indonesia
In February 2010, Indonesia made a high-level political commitment to work with the FATF and the APG to address its strategic AML/CFT
deficiencies. Since June, Indonesia has taken steps towards improving its AML/CFT regime, including by approving a new AML law on October
2010. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Indonesia should continue to work on
implementing its action plan to address these deficiencies, including by: (1) adequately criminalising terrorist financing (Special
Recommendation II); (2) ensuring effective criminalisation of money laundering (Recommendation 1); (2) establishing and implementing
adequate procedures to identify and freeze terrorist assets (Special Recommendation III); and (3) amending and implementing laws or other
instruments to fully implementing the 1999 International Convention for the Suppression of Financing of Terrorism (Special Recommendation I).
The FATF encourages Indonesia to address its remaining deficiencies and continue the process of implementing its action plan.
Kenya
In February 2010, Kenya made a high-level political commitment to work with the FATF and ESAAMLG to address its strategic AML/CFT
deficiencies. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Kenya should continue to work on
implementing its action plan to address these deficiencies, including by: (1) adequately criminalising terrorist financing (Special
Recommendation II); (2) ensuring a fully operational and effectively functioning Financial Intelligence Unit (Recommendation 26); (3)
establishing and implementing an adequate legal framework for identifying and freezing terrorist assets (Special Recommendation III); (4) raising
awareness of AML/CFT issues within the law enforcement community (Recommendation 27); and (5) implementing effective, proportionate and
dissuasive sanctions in order to deal with natural or legal persons that do not comply with the national AML/CFT requirements (Recommendation
17). The FATF encourages Kenya to address its remaining deficiencies and continue the process of implementing its action plan.
Morocco
In February 2010, Morocco made a high-level political commitment to work with the FATF and MENAFATF to address its strategic AML/CFT
deficiencies. Since June, Morocco has taken steps towards improving its AML/CFT regime, including by taking initial steps to make the FIU more
operational. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Morocco should continue to work on
implementing its action plan to address these deficiencies, including by: (1) amending the penal code to extend the scope of the ML and FT
offences (Recommendation 1 and Special Recommendation II); (2) amending relevant laws or regulations to address deficiencies in customer
due diligence requirements (Recommendation 5); and (3) ensuring a fully operational and effectively functioning Financial Intelligence Unit
(Recommendation 26). The FATF encourages Morocco to address its remaining deficiencies and continue the process of implementing its
action plan.
Myanmar
In February 2010, Myanmar made a high-level political commitment to work with the FATF and APG to address its strategic AML/CFT
deficiencies. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Myanmar should continue to work on
implementing its action plan to address these deficiencies, including by: (1) adequately criminalising money laundering and terrorist financing
(Recommendation 1 and Special Recommendation II); (2) establishing and implementing adequate procedures to identify and freeze terrorist
assets (Special Recommendation III); (3) strengthening the extradition framework in relation to terrorist financing (Recommendation 35 and
Special Recommendation I); (4) ensuring a fully operational and effectively functioning Financial Intelligence Unit (Recommendation 26); (5)
enhancing financial transparency (Recommendation 4); and (6) strengthening customer due diligence measures (Recommendations 5). The
FATF encourages Myanmar to address its remaining deficiencies and continue the process of implementing its action plan.
Nepal
In February 2010, Nepal made a high-level political commitment to work with the FATF and APG to address its strategic AML/CFT deficiencies.
Since June, Nepal has taken steps towards improving its AML/CFT regime, including by tabling draft amendments on money laundering and
terrorist financing. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Nepal should continue to work on
implementing its action plan to address these deficiencies, including by: (1) adequately criminalising money laundering and terrorist financing
(Recommendation 1 and Special Recommendation II); (2) establishing and implementing adequate procedures to identify and freeze terrorist
assets (Special Recommendation III); (3) implementing adequate procedures for the confiscation of funds related to money laundering
(Recommendation 3); and (4) enacting and implementing appropriate mutual legal assistance legislation (Recommendation 36). The FATF
encourages Nepal to address its remaining deficiencies and continue the process of implementing its action plan.
Nigeria
In February 2010, Nigeria made a high-level political commitment to work with the FATF and GIABA to address its strategic AML/CFT
deficiencies. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Nigeria should continue to work on
implementing its action plan to address these deficiencies, including by: (1) adequately criminalising money laundering and terrorist financing
(Recommendation 1 and Special Recommendation II); (2) implementing adequate procedures to identify and freeze terrorist assets (Special
Recommendation III); (3) ensuring that relevant laws or regulations address deficiencies in customer due diligence requirements and that they
apply to all financial institutions (Recommendation 5); and (4) demonstrating that AML/CFT supervision is undertaken effectively across the
financial sector (Recommendation 23). The FATF encourages Nigeria to address its remaining deficiencies and continue the process of
implementing its action plan.
Pakistan
In June 2010, Pakistan made a high-level political commitment to work with the FATF and APG to address its strategic AML/CFT deficiencies.
Since June, Pakistan has taken steps towards improving its AML/CFT regime, including by broadening the scope of ML predicate offences.
However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Pakistan will work on implementing its action plan to
address these deficiencies, including by (1) demonstrating adequate criminalisation of money laundering and terrorist financing
(Recommendation 1 and Special Recommendation II); (2) demonstrating adequate procedures to identify, freeze and confiscate terrorist assets
(Special Recommendation III); (3) ensuring a fully operational and effectively functioning Financial Intelligence Unit (Recommendation 26); (4)
demonstrating effective regulation of money service providers, including an appropriate sanctions regime, and increasing the range of ML/FT
preventive measures for these services (Special Recommendation VI); and (5) improving and implementing effective controls for cross-border
cash transactions (Special Recommendation IX). The FATF encourages Pakistan to address its remaining deficiencies and continue the process
of implementing its action plan.
Paraguay
In February 2010, Paraguay made a high-level political commitment to work with the FATF and GAFISUD to address its strategic AML/CFT
deficiencies. Since June, Paraguay has taken steps towards improving its AML/CFT regime, including by establishing some fundamental CDD
measures. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Paraguay should continue to work on
implementing its action plan to address these deficiencies, including by: (1) establishing and implementing adequate procedures to identify,
freeze and confiscate terrorist assets (Special Recommendation III); (2) improving financial transparency (Recommendation 4); (3) improving
and broadening customer due diligence measures (Recommendation 5); and (4) implementing effective controls for cross-border cash
transactions (Special Recommendation IX). The FATF encourages Paraguay to address its remaining deficiencies and continue the process of
implementing its action plan.
Philippines
In October 2010, the Philippines made a high-level political commitment to work with the FATF and APG to address its strategic AML/CFT
deficiencies. The Philippines has taken steps towards improving its AML/CFT regime. However, the FATF has determined that certain strategic
AML/CFT deficiencies remain. The Philippines will work on implementing its action plan to address these deficiencies, including by: (1)
adequately criminalising money laundering and terrorist financing (Recommendation 1 and Special Recommendation II); (2) implementing
adequate procedures to identify and freeze terrorist assets and confiscate funds related to money laundering (Special Recommendation III and
Recommendation 3); (3) enhancing financial transparency (Recommendation 4); (4) ensuring capacity and financial resources for competent
authorities (Recommendation 30); and (5) establishing effective CDD measures (Recommendation 5). The FATF encourages the Philippines to
address its remaining deficiencies and continue the process of implementing its action plan.
São Tomé and Príncipe
In October 2010, São Tomé and Príncipe made a high-level political commitment to work with the FATF and GIABA to address its strategic
AML/CFT deficiencies. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. São Tomé and Príncipe will work
on implementing its action plan to address these deficiencies, including by: (1) adequately criminalising money laundering and terrorist financing
(Recommendation 1 and Special Recommendation II); (2) establishing a fully operational and effectively functioning Financial Intelligence Unit
(Recommendation 26); (3) ensuring that financial institutions and DNFBPs are subject to adequate AML/CFT regulation and supervision, and
that competent authority or authorities have been designated to ensure compliance with AML/CFT requirements (Recommendations 23, 24 and
29); (4) implementing effective, proportionate and dissuasive sanctions in order to deal with natural or legal persons that do not comply with the
national AML/CFT requirements (Recommendation 17); and (5) taking the necessary action to gain membership of GIABA. The FATF
encourages São Tomé and Príncipe to address its remaining deficiencies and continue the process of implementing its action plan.
Sri Lanka
In February 2010, Sri Lanka made a high-level political commitment to work with the FATF and APG to address its strategic AML/CFT
deficiencies. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Sri Lanka should continue to work on
implementing its action plan to address these deficiencies, including by: (1) adequately criminalising money laundering and terrorist financing
(Recommendation 1 and Special Recommendation II); and (2) establishing and implementing adequate procedures to identify and freeze
terrorist assets (Special Recommendation III). The FATF encourages Sri Lanka to address its remaining deficiencies and continue the process
of implementing its action plan.
Sudan
In February 2010, Sudan made a high-level political commitment to work with the FATF and MENAFATF to address its strategic AML/CFT
deficiencies. Since June, Sudan has taken steps towards improving its AML/CFT regime, including by conducting outreach to financial
institutions on AML/CFT obligations and taking initial steps to operationalise the FIU. However, the FATF has determined that certain strategic
AML/CFT deficiencies remain. Sudan should continue to work on implementing its action plan to address these deficiencies, including by: (1)
implementing adequate procedures for identifying and freezing terrorist assets (Special Recommendation III); (2) ensuring a fully operational
and effectively functioning Financial Intelligence Unit (Recommendation 26); (3) ensuring financial institutions are aware of and comply with their
obligations to file suspicious transaction reports in relation to ML and FT (Recommendation 13 and Special Recommendation IV); and (4)
implementing a supervisory programme for the regulators to ensure compliance with the provisions of the new law and regulations
(Recommendation 23). The FATF encourages Sudan to address its remaining deficiencies and continue the process of implementing its action
plan.
Syria
In February 2010, Syria made a high-level political commitment to work with the FATF and MENAFATF to address its strategic AML/CFT
deficiencies. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Syria should continue to work on
implementing its action plan to address these deficiencies, including by: (1) adopting adequate measures to implement and enforce the 1999
International Convention for the Suppression of Financing of Terrorism (Special Recommendation I); (2) adequately criminalising terrorist
financing (Special Recommendation II); (3) implementing adequate procedures for identifying and freezing terrorist assets (Special
Recommendation III); (4) ensuring financial institutions are aware of and comply with their obligations to file suspicious transaction reports in
relation to ML and FT (Recommendation 13 and Special Recommendation IV) and (5) adopting appropriate laws and procedures to provide
mutual legal assistance (Recommendations 36-38, Special Recommendation V). The FATF encourages Syria to address its remaining
deficiencies and continue the process of implementing its action plan.
Tanzania
In October 2010, Tanzania made a high-level political commitment to work with the FATF and ESAAMLG to address its strategic AML/CFT
deficiencies. Tanzania has taken steps towards improving its AML/CFT regime. However, the FATF has determined that certain strategic
AML/CFT deficiencies remain. Tanzania will work on implementing its action plan to address these deficiencies, including by: (1) adequately
criminalising money laundering and terrorist financing (Recommendation 1 and Special Recommendation II); (2) establishing and implementing
adequate procedures to identify and freeze terrorist assets as well as implementing the UNSCR 1267 and 1373 through law, regulations or
other enforceable means (Special Recommendation III); (3) establishing effective CDD measures (Recommendation 5); (4) establishing
adequate record-keeping requirements (Recommendation 10); (5) establishing a fully operational and effectively functioning national Financial
Intelligence Unit (Recommendation 26); and (6) designating competent authorities to ensure compliance with AML/CFT requirements
(Recommendation 23). The FATF encourages Tanzania to address its remaining deficiencies and continue the process of implementing its
action plan.
Thailand
In February 2010, Thailand made a high-level political commitment to work with the FATF and APG to address its strategic AML/CFT
deficiencies. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Thailand should continue to work on
implementing its action plan to address these deficiencies, including by: (1) adequately criminalising terrorist financing (Special
Recommendation II); (2) establishing and implementing adequate procedures to identify and freeze terrorist assets (Special Recommendation
III); and (3) further strengthening AML/CFT supervision (Recommendation 23). The FATF encourages Thailand to address its remaining
deficiencies and continue the process of implementing its action plan.
Trinidad and Tobago
In February 2010, Trinidad and Tobago made a high-level political commitment to work with the FATF and CFATF to address its strategic
AML/CFT deficiencies. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Trinidad and Tobago should
continue to work on implementing its action plan to address these deficiencies, including by: (1) implementing adequate procedures to identify
and freeze terrorist assets without delay (Special Recommendation III); (2) implementing adequate procedures for the confiscation of funds
related to money laundering (Recommendation 3); and (3) establishing a fully operational and effectively functioning FIU, including supervisory
powers (Recommendation 26). The FATF encourages Trinidad and Tobago to address its remaining deficiencies and continue the process of
implementing its action plan.
Turkey
In February 2010, Turkey made a high-level political commitment to work with the FATF to address its strategic AML/CFT deficiencies. Since
June, Turkey has taken steps towards improving its AML/CFT regime, including by working on draft CFT legislation. However, the FATF has
determined that certain strategic AML/CFT deficiencies remain. Turkey should continue to work on implementing its action plan to address these
deficiencies, including by: (1) adequately criminalising terrorist financing (Special Recommendation II); and (2) implementing an adequate legal
framework for identifying and freezing terrorist assets (Special Recommendation III). The FATF encourages Turkey to address its remaining
deficiencies and continue the process of implementing its action plan.
Turkmenistan
In June 2010, Turkmenistan made a high-level political commitment to work with the FATF and EAG to address its strategic AML/CFT
deficiencies. Since June, Turkmenistan has taken steps towards improving its AML/CFT regime, including by holding training workshops to build
the capacity of its FIU. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Turkmenistan will work on
implementing its action plan to address these deficiencies, including by: (1) addressing the remaining issues with the criminalisation of money
laundering and terrorist financing (Recommendation 1 and Special Recommendation II), (2) implementing adequate procedures to identify and
freeze terrorist assets without delay (Special Recommendation III); (3) ensuring a fully operational and effectively functioning FIU
(Recommendation 26), (4) developing collaboration between the FIU and domestic counterparts, including supervisory authorities, and (5)
strengthening international cooperation. The FATF encourages Turkmenistan to address its remaining deficiencies and continue the process of
implementing its action plan.
Ukraine
In February 2010, Ukraine made a high-level political commitment to work with the FATF and MONEYVAL to address its strategic AML/CFT
deficiencies. Since June, Ukraine has taken steps towards improving its AML/CFT regime, including by bringing a new AML/CFT law into force.
However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Ukraine should continue to work on implementing its
action plan to address these deficiencies, including by: (1) addressing remaining issues regarding criminalisation of money laundering
(Recommendation 1); and (2) improving and implementing an adequate legal framework for identifying and freezing terrorist assets (Special
Recommendation III). The FATF encourages Ukraine to address its remaining deficiencies and continue the process of implementing its action
plan.
Venezuela
In October 2010, Venezuela made a high-level political commitment to work with the FATF and CFATF to address its strategic AML/CFT
deficiencies. Venezuela has taken steps towards improving its AML/CFT regime. However, the FATF has determined that certain strategic
deficiencies remain. Venezuela will work with the FATF and CFATF on implementing its action plan to address these deficiencies, including by:
(1) adequately criminalising terrorist financing (Special Recommendation II); (2) establishing and implementing adequate procedures to identify
and freeze terrorist assets (Special Recommendation III); (3) ensuring a fully operational and effectively functioning Financial Intelligence Unit
(Recommendation 26); (4) implementing adequate CDD guidelines for all sectors (Recommendation 5); and (5) establishing adequate STR
reporting obligations for ML and TF (Recommendation 13 and Special Recommendation IV). The FATF encourages Venezuela to address its
remaining deficiencies and continue the process of implementing its action plan.
Vietnam
In October 2010, Vietnam made a high-level political commitment to work with the FATF to address its strategic AML/CFT deficiencies. Vietnam
has taken steps towards improving its AML/CFT regime. However, the FATF has determined that certain strategic AML/CFT deficiencies remain.
Vietnam will work with the FATF and the APG on implementing its action plan to address these deficiencies, including by: (1) adequately
criminalising money laundering and terrorist financing (Recommendation 1 and Special Recommendation II); (2) establishing and implementing
adequate procedures to identify and freeze terrorist assets (Special Recommendation III); (3) improving the overall supervisory framework
(Recommendation 23); (4) improving and broadening customer due diligence measures and reporting requirements (Recommendation 5, 13,
and Special Recommendation IV); and (5) strengthening international cooperation (Recommendations 36, 40). The FATF encourages Vietnam
to address its remaining deficiencies and continue the process of implementing its action plan.
Yemen
In February 2010, Yemen made a high-level political commitment to work with the FATF and MENFATF to address its strategic AML/CFT
deficiencies. However, the FATF has determined that certain strategic deficiencies remain. Yemen should continue to work on implementing its
action plan to address these deficiencies, including by: (1) issue regulations to implement AML law; (2) establishing and implementing adequate
procedures to identify and freeze terrorist assets (Special Recommendation III); (3) issuing substantive guidance/instructions to reporting
institutions with respect to their ML/FT obligations (Recommendation 25); (4) developing the monitoring and supervisory capacity of the financial
sector supervisory authorities and the FIU, to ensure compliance by financial institutions with their STR obligations, especially in relation to FT
(Recommendation 23); and (5) ensuring a fully operational and effectively functioning Financial Intelligence Unit (Recommendation 26). The
FATF encourages Yemen to address its remaining deficiencies and continue the process of implementing its action plan.
In February 2010, the FATF identified the following jurisdictions as having strategic AML/CFT deficiencies. Since then, they have substantially
addressed the strategic deficiencies identified in their action plans and will be removed from this FATF monitoring process. The jurisdictions will
continue to work with their respective FSRBs to improve their AML/CFT regimes.
Qatar
The FATF welcomes Qatar’s significant progress in improving its AML/CFT regime and notes that Qatar has met its commitments in its Action
Plan regarding the strategic AML/CFT deficiencies that the FATF had identified in February 2010. Qatar is therefore no longer subject to FATF’s
monitoring process under its ongoing global AML/CFT compliance process. Qatar will work with MENAFATF as it continues to address the full
range of AML/CFT issues identified in its Mutual Evaluation Report, in particular compliance with Special Recommendation III (adequate
procedures to identify and freeze terrorist assets).
Azerbaijan
The FATF welcomes Azerbaijan’s significant progress in improving its AML/CFT regime and notes that Azerbaijan has met its commitments in its
Action Plan regarding the strategic AML/CFT deficiencies that the FATF had identified in February 2010. Azerbaijan is therefore no longer
subject to FATF’s monitoring process under its ongoing global AML/CFT compliance process. Azerbaijan will work with MONEYVAL as it
continues to address the full range of AML/CFT issues identified in its Mutual Evaluation Report, particularly compliance with SRIII (adequate
procedures to identify and freeze terrorist assets).
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