28 October 2011 - 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 works with them to address those deficiencies
that pose a risk to the international financial system.
Jurisdictions subject to a FATF call on its members and other jurisdictions to apply counter-measures to protect the international financial
system from the on-going and substantial money laundering and terrorist financing (ML/TF) risks emanating from the jurisdictions*.
Iran
Democratic People's Republic of Korea (DPRK)
Jurisdictions with strategic AML/CFT deficiencies 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**. The FATF calls on its members to consider the risks arising from the
deficiencies associated with each jurisdiction, as described below.
Cuba**
Bolivia
Ethiopia
Kenya
Myanmar
Nigeria
São Tomé and Príncipe
Sri Lanka
Syria
Turkey
* The FATF has previously issued public statements calling for counter-measures on Iran and DPRK. Those statements are updated below.
**Cuba has not engaged with the FATF in the process.
Iran
The FATF, with a renewed urgency, is particularly and exceptionally 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, despite Iran’s engagement with the FATF.
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. Due to the
continuing terrorist financing threat emanating from Iran, jurisdictions should consider the steps already taken and possible additional
safeguards or strengthen existing ones.
The FATF urges Iran to immediately and meaningfully address its AML/CFT deficiencies, in particular by criminalising terrorist financing and
effectively implementing suspicious transactions reporting (STR) requirements. If Iran fails to take concrete steps to improve its CFT regime, the
FATF will consider calling on its members and urging all jurisdictions to strengthen counter-measures in February 2012.
Democratic People's Republic of Korea (DPRK)
The FATF remains concerned by the DPRK’s failure to address the significant deficiencies in its anti-money laundering and combating the
financing of terrorism (AML/CFT) regime and the serious threat this poses to the integrity of the international financial system. The FATF urges
the DPRK to immediately and meaningfully address its AML/CFT deficiencies.
The FATF reaffirms its call on its members and urges all jurisdictions to advise their financial institutions to give special attention to business
relationships and transactions with the DPRK, including DPRK companies and financial institutions. In addition to enhanced scrutiny, the FATF
further calls 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 the DPRK. Jurisdictions should also protect against correspondent
relationships being used to bypass or evade counter-measures and risk mitigation practices, and take into account ML/FT risks when
considering requests by DPRK financial institutions to open branches and subsidiaries in their jurisdiction.
The FATF remains prepared to engage directly in assisting the DPRK to address its AML/CFT deficiencies, including through the FATF
Secretariat.
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Cuba
Cuba has not committed to the AML/CFT international standards, nor has it constructively engaged with the FATF. The FATF has identified Cuba
as having strategic AML/CFT deficiencies that pose a risk to the international financial system. The FATF urges Cuba to develop an AML/CFT
regime in line with international standards, and is ready to work with the Cuban authorities to this end.
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Bolivia
Bolivia has taken steps towards improving its AML/CFT regime, including by enacting new CFT legislation. However, despite Bolivia’s high-level
political commitment to work with the FATF and GAFISUD to address its strategic AML/CFT deficiencies, Bolivia has not made sufficient progress
in implementing its action plan, and certain strategic AML/CFT deficiencies remain. Bolivia should work on addressing these deficiencies
including by: (1) ensuring adequate criminalisation of money laundering (Recommendation 1); (2) adequately criminalising 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.
Ethiopia
Despite Ethiopia’s high-level political commitment to work with the FATF to address its strategic AML/CFT deficiencies, Ethiopia has not made
sufficient progress in implementing its action plan, and certain strategic AML/CFT deficiencies remain. Ethiopia should work on addressing 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.
Kenya
Despite Kenya’s high-level political commitment to work with the FATF and ESAAMLG to address its strategic AML/CFT deficiencies, Kenya has
not made sufficient progress in implementing its action plan, and certain strategic AML/CFT deficiencies remain. Kenya should work on
addressing 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, including by implementing the AML legislation and
setting up its FIU.
Myanmar
Despite Myanmar’s high-level political commitment to work with the FATF and APG to address its strategic AML/CFT deficiencies, Myanmar has
not made sufficient progress in implementing its action plan, and certain strategic AML/CFT deficiencies remain. Myanmar should work on
addressing 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) further 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 (Recommendation 5). The FATF encourages Myanmar to address its remaining deficiencies and continue the
process of implementing its action plan.
Nigeria
Nigeria has taken steps towards improving its AML/CFT regime, including by enacting AML/CFT legislation. However, despite Nigeria’s high-level
political commitment to work with the FATF and GIABA to address its strategic AML/CFT deficiencies, Nigeria has not made sufficient progress in
implementing its action plan, and certain strategic deficiencies remain. Nigeria should work on addressing 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) continuing to
improve the overall supervisory framework for AML/CFT (Recommendation 23). The FATF encourages Nigeria to address its remaining
deficiencies and continue the process of implementing its action plan.
São Tomé and Príncipe
Despite São Tomé and Príncipe’s high-level political commitment to work with the FATF to address its strategic AML/CFT deficiencies, São Tomé
and Príncipe has not made sufficient progress in implementing its action plan, and certain strategic deficiencies remain. São Tomé and Príncipe
should work on addressing 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 a competent authority or competent 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
Sri Lanka has taken steps towards improving its AML/CFT regime, including by enacting AML/CFT amendments. However, despite Sri Lanka’s
high-level political commitment to work with the FATF and APG to address its strategic AML/CFT deficiencies, Sri Lanka has not made sufficient
progress in implementing its action plan, and certain strategic AML/CFT deficiencies remain. Sri Lanka should work on addressing these
deficiencies, including by: (1) adequately criminalising terrorist financing and addressing the remaining deficiencies with regard to the
criminalisation of money laundering (Special Recommendation II and Recommendation 1); 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, including by continuing to work on its AML/CFT legislation.
Syria
Syria has taken significant steps towards improving its AML/CFT regime, including by improving the legal arrangements for freezing terrorist
assets. However, despite Syria’s high-level political commitment to work with the FATF and MENAFATF to address its strategic AML/CFT
deficiencies, Syria has not made sufficient progress in implementing its action plan, and certain strategic AML/CFT deficiencies remain. Syria
should work on addressing its 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) implementing adequate procedures for identifying
and freezing terrorist assets (Special Recommendation III); (3) ensuring that 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) ensuring that
appropriate laws and procedures are in place 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.
Turkey
Turkey has taken steps towards improving its AML/CFT regime, including by submitting CFT legislation to Parliament. Despite Turkey’s high-
level political commitment to work with the FATF to address its strategic AML/CFT deficiencies, Turkey has not made sufficient progress in
implementing its action plan, and certain strategic AML/CFT deficiencies remain. Turkey should work on addressing 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.
As part of its on-going 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. The 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 on-going
basis, that pose a risk to the international financial system. 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.
Algeria
In October 2011, Algeria made a high-level political commitment to work with the FATF and MENAFATF to address its strategic AML/CFT
deficiencies. Algeria has taken steps towards improving its AML/CFT regime. However, the FATF has determined that certain strategic AML/CFT
deficiencies remain. Algeria will work on implementing its action plan to address these deficiencies, including by: (1) adequately criminalising
terrorist financing (Special Recommendations I and II); (2) establishing and implementing an adequate legal framework for identifying, tracing
and freezing terrorist assets (Special Recommendation III), (3) improving and broadening CDD measures and ensuring that they apply to all
financial institutions (Recommendation 5); (4) ensuring a fully operational and effectively functioning Financial Intelligence Unit, in particular
addressing the operational autonomy of the FIU and the authority of the FIU to request and access information (Recommendation 26); and (5)
enacting and implementing appropriate mutual legal assistance legislation (Special Recommendation V). The FATF encourages Algeria to
address its deficiencies and continue the process of implementing its action plan.
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
2011, Angola has taken steps towards improving its AML/CFT regime, including by issuing CDD regulations to banks. However, the FATF has
determined that certain strategic AML/CFT deficiencies remain. Angola 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) ensuring a fully operational and effectively functioning Financial Intelligence Unit (Recommendation 26); and (3)
establishing and implementing an adequate legal framework for identifying, tracing and freezing terrorist assets (Special Recommendation III).
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 2011, Antigua and Barbuda has taken steps towards improving its AML/CFT regime, including by
commencing off-site inspections of its financial institutions. 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); and (2) continuing to
improve the overall supervisory framework (Recommendation 23). The FATF encourages Antigua and Barbuda to address its remaining
deficiencies and continue the process of implementing its action plan.
Argentina
In June 2011, Argentina made a high-level political commitment to work with the FATF to address its strategic AML/CFT deficiencies. Since then,
Argentina has taken steps towards improving its AML/CFT regime, including by addressing some of the concerns the FATF expressed regarding
its June 2011 amendments to its AML legislation, submitting draft CFT legislation to National Congress, issuing a decree dealing with evaluating
effectiveness of its AML/CFT measures; and issuing an FIU Resolution enhancing CDD measures for the financial and foreign exchange sectors.
The FATF has determined that strategic AML/CFT deficiencies remain. Argentina will work on implementing its action plan to address these
deficiencies, including by: (1) adequately criminalising terrorist financing and addressing the remaining deficiencies with regard to the
criminalisation of money laundering (Special Recommendation II and Recommendation 1); (2) establishing and implementing adequate
procedures for the confiscation of funds related to money laundering and identifying and freezing terrorist assets (Recommendation 3 and
Special Recommendation III); (3) enhancing financial transparency (Recommendation 4); (4) ensuring a fully operational and effectively
functioning Financial Intelligence Unit and improving suspicious transaction reporting requirements (Recommendation 13, Special
Recommendation IV and Recommendation 26); (5) implementing an adequate AML/CFT supervisory programme for all financial sectors
(Recommendations 17, 23 and 29); (6) improving and broadening CDD measures for the non-banking or non-foreign exchange sectors
(Recommendation 5); and (7) establishing appropriate channels for international co-operation and ensuring effective implementation
(Recommendation 36, Recommendation 40 and Special Recommendation V). The FATF encourages Argentina 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. Since June 2011, Bangladesh has taken steps towards improving its AML/CFT regime, including by issuing AML/CFT guidance
notes for the insurance sector. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Bangladesh 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); (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
co-operation (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.
Brunei Darussalam
In June 2011, Brunei Darussalam made a high-level political commitment to work with the FATF and APG to address its strategic AML/CFT
deficiencies. Since then, Brunei Darussalam has taken steps towards improving its AML/CFT regime, including by enacting an Anti-Terrorism
Order in July 2011. However, the FATF has determined that strategic AML/CFT deficiencies remain. Brunei Darussalam 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) establishing and implementing adequate procedures for the confiscation of funds related to money
laundering (Recommendation 3); (4) improving suspicious transaction reporting requirements (Recommendation 13 and Special
Recommendation IV); (5) ensuring a fully operational and effectively functioning Financial Intelligence Unit (Recommendation 26); and (6)
enacting and implementing appropriate mutual legal assistance legislation (Recommendation 36 and Special Recommendation V). The FATF
encourages Brunei Darussalam to address its remaining deficiencies and continue the process of implementing its action plan.
Cambodia
In June 2011, Cambodia made a high-level political commitment to work with the FATF and APG to address its strategic AML/CFT deficiencies.
The FATF has determined that strategic AML/CFT deficiencies remain. Cambodia 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) establishing and 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); and (5) establishing and implementing
effective controls for cross-border cash transactions (Special Recommendation IX). The FATF encourages Cambodia 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. The FATF has determined that certain strategic AML/CFT deficiencies remain. Ecuador should continue to work on implementing its
action plan to address these deficiencies, including by: (1) ensuring adequate criminalisation of terrorist financing (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 co-
ordination of financial sector supervision (Recommendation 23). The FATF encourages Ecuador 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. Since that time, Honduras has demonstrated progress in improving its AML/CFT regime, including by adopting legislation that aims
to address issues relating to criminalisation of terrorist financing and freezing of terrorist assets and implementing resolutions that aim to
improve CDD measures. The FATF will conduct an on-site visit to confirm that the process of implementing the required reforms and actions is
underway to address deficiencies previously identified by the FATF.
Kyrgyzstan
In October 2011, Kyrgyzstan made a high-level political commitment to work with the FATF and EAG to address its strategic AML/CFT
deficiencies. Kyrgyzstan has taken steps towards improving its AML/CFT regime. However, the FATF has determined that certain strategic
AML/CFT deficiencies remain. Kyrgyzstan 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 for identifying, tracing and freezing terrorist assets (Special Recommendation III) (3) establishing and
implementing adequate measures for the confiscation of funds related to money laundering (Recommendation 3); (4) establishing effective CDD
measures for all financial institutions (Recommendation 5); and (5) implementing an adequate and effective AML/CFT supervisory programme
for all financial sectors (Recommendation 23). The FATF encourages Kyrgyzstan to address its deficiencies and continue the process of
implementing its action plan.
Mongolia
In June 2011, Mongolia made a high-level political commitment to work with the FATF and APG to address its strategic AML/CFT deficiencies.
The FATF has determined that strategic AML/CFT deficiencies remain. Mongolia 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) establishing adequate procedures for the confiscation of funds related to money laundering (Recommendation 3); (4) establishing
suspicious transaction reporting requirements (Recommendation 13 and Special Recommendation IV); (5) establishing a fully operational and
effectively functioning Financial Intelligence Unit (Recommendation 26); and (6) demonstrating effective regulation of money service providers.
The FATF encourages Mongolia 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 then, Morocco has demonstrated progress in improving its AML/CFT regime, including by adopting amendments to extend
the scope of the money laundering and terrorist financing offences; to broaden customer due diligence requirements and taking steps to
operationalise the Financial Intelligence Unit. 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 adequately criminalising terrorist financing
(Special Recommendation II).
Namibia
In June 2011, Namibia made a high-level political commitment to work with the FATF and ESAAMLG to address its strategic AML/CFT
deficiencies. Namibia has taken steps towards improving its AML/CFT regime, including by securing the information held in the FIU. However,
the FATF has determined that strategic AML/CFT deficiencies remain. Namibia 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); (3) implementing an adequate AML/CFT
supervisory programme with sufficient powers (Recommendation 23 and 29); (4) ensuring a fully operational and effectively functioning
Financial Intelligence Unit, in particular addressing the operational autonomy of the FIU (Recommendation 26); (5) implementing effective,
proportionate and dissuasive sanctions in order to deal with non-compliance with the national AML/CFT requirements (Recommendation 17);
and (6) implementing the 1999 International Convention for the Suppression of Financing of Terrorism (Special Recommendation I). The FATF
encourages Namibia 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 2011, Nepal has taken steps towards improving its AML/CFT regime, including by approving an AML/CFT National Strategy.
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.
Nicaragua
In June 2011, Nicaragua made a high-level political commitment to work with the FATF and CFATF to address its strategic AML/CFT deficiencies.
Since then, Nicaragua has taken steps towards improving its AML/CFT regime, including by establishing an agency responsible for regulating
and supervising the microfinance industry. However, the FATF has determined that strategic AML/CFT deficiencies remain. Nicaragua should
continue to work on implementing its action plan to address these deficiencies, including by: (1) establishing effective CDD measures and
record-keeping requirements, in particular entities not currently regulated by the supervisory authority (Recommendation 5 and
Recommendation 10); (2) establishing adequate STR reporting obligations for ML and FT (Recommendation 13 and Special Recommendation
IV); (3) implementing an adequate AML/CFT supervisory programme for all financial sectors (Recommendation 23); (4) establishing a fully
operational and effectively functioning Financial Intelligence Unit (Recommendation 26); and (5) establishing adequate procedures for
identifying and freezing terrorist assets (Special Recommendation III)The FATF encourages Nicaragua 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 that time, Paraguay has taken steps towards improving its AML/CFT regime, including enacting CFT legislation and issuing
regulations prohibiting anonymous accounts. The FATF will conduct an on-site visit to confirm that the process of implementing the required
reforms and actions is underway to address deficiencies previously identified by the FATF.
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. Since June 2011, the Philippines has taken steps towards improving its AML/CFT regime, including by capacity building in the
areas of supervision and regulation. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. The Philippines
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 and confiscate funds related to money laundering (Special Recommendation III and Recommendation 3); (3) enhancing
financial transparency (Recommendation 4); and (4) extending coverage of reporting entities (Recommendations 12 and 16). The FATF
encourages the Philippines 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 2011, Sudan has taken steps towards improving its AML/CFT regime, including by improving the overall infrastructure
of the FIU and the supervisory framework. 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 that 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.
Tajikistan
In June 2011, Tajikistan made a high-level political commitment to work with the FATF and EAG to address its strategic AML/CFT deficiencies.
The FATF has determined that strategic AML/CFT deficiencies remain. Tajikistan 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 for the confiscation of funds related to money laundering and
identifying and freezing terrorist assets (Recommendation 3 and Special Recommendation III); (3) enhancing financial transparency
(Recommendation 4); (4) ensuring a fully operational, and effectively functioning Financial Intelligence Unit and improving suspicious transaction
reporting requirements (Recommendation 13, Special Recommendation IV, and Recommendation 26); and (5) improving and broadening CDD
measures (Recommendation 5). The FATF encourages Tajikistan 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 2011, Turkmenistan has taken steps towards improving its AML/CFT regime, including by establishing a legal
framework to freeze terrorist assets. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Turkmenistan
should continue to work on implementing its action plan to address these deficiencies, including by: (1) developing collaboration between the
FIU and domestic counterparts, including supervisory authorities; and (2) strengthening international co-operation in the areas of investigation
and confiscation/repatriation of funds. The FATF encourages Turkmenistan 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. Since June 2011, Trinidad and Tobago has taken steps towards improving its AML/CFT regime, including by completing
the registration process of the listed businesses and initiating the supervision of the listed entities. 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); and (2) establishing a fully operational and effectively functioning Financial Intelligence Unit, 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.
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. Since then, Venezuela has taken steps towards improving its AML/CFT regime, including by improving the independence of the FIU
and the regulations for the banking and securities sectors. However, the FATF has determined that certain strategic deficiencies remain.
Venezuela should continue to 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 Recommendations I and 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 FT (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 and APG to address its strategic AML/CFT deficiencies.
The FATF has determined that certain strategic AML/CFT deficiencies remain. Vietnam should continue to work with the FATF and 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) making legal persons subject to criminal liability in line with FATF Recommendation 2 or demonstrating
that there is a constitutional prohibition to prevent this; (4) improving the overall supervisory framework (Recommendation 23); (5) improving
and broadening customer due diligence measures and reporting requirements (Recommendation 5, 13, and Special Recommendation IV); and
(6) strengthening international co-operation (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 MENAFATF to address its strategic AML/CFT
deficiencies. 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) establishing and implementing adequate procedures to identify and freeze terrorist assets
(Special Recommendation III); (2) conducting outreach to sensitise reporting institutions of their AML/CFT obligations (Recommendation 25); (3)
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 (4) 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.
Zimbabwe
In June 2011, Zimbabwe made a high-level political commitment to work with the FATF and ESAAMLG to address its strategic AML/CFT
deficiencies. The FATF has determined that strategic AML/CFT deficiencies remain. Zimbabwe should continue to work on implementing its
action plan to address these deficiencies, including by: (1) adequately criminalising money laundering and terrorist financing (Recommendation I
and 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) ensuring
that 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); (5) enacting and implementing appropriate mutual legal assistance legislation (Special
Recommendation V); and (6) implementing the 1999 International Convention for the Suppression of Financing of Terrorism (Special
Recommendation I). The FATF encourages Zimbabwe to address its remaining deficiencies and continue the process of implementing its action
plan.
The following Country is no longer subject to FATF’s monitoring process under its on-going global AML/CFT compliance
process.
Ukraine
The FATF welcomes Ukraine’s significant progress in improving its AML/CFT regime and notes that Ukraine has largely met its commitments in
its Action Plan regarding the strategic deficiencies that the FATF had identified in February 2010. Ukraine is therefore no longer subject to FATF’
s monitoring process under its on-going global AML/CFT compliance process. Ukraine will work with MONEYVAL as it continues to address the
full range of AML/CFT issues identified in its Mutual Evaluation Report, and further strengthen its AML/CFT regime.
Jurisdiction not making sufficient progress
The FATF is not yet satisfied that the following jurisdictions have made sufficient progress on their action plan agreed upon with the FATF. The
most significant action plan items and/or the majority of the action plan items have not been addressed. If these jurisdictions do not take
sufficient action to implement significant components of their action plan by February 2012, then the FATF will identify these jurisdictions as
being out of compliance with their agreed action plans and will take the additional step of calling upon its members to consider the risks arising
from the deficiencies associated with the jurisdiction.
Ghana
Despite Ghana’s high-level political commitment to work with the FATF and GIABA to address its strategic AML/CFT deficiencies, the FATF is not
yet satisfied that Ghana has made sufficient progress in implementing its action plan, and certain strategic AML/CFT deficiencies remain. Ghana
should work with the FATF and GIABA 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.
Indonesia
Despite Indonesia’s high-level political commitment to work with the FATF and APG to address its strategic AML/CFT deficiencies, the FATF is
not yet satisfied that Indonesia has made sufficient progress in implementing its action plan, and certain strategic AML/CFT deficiencies remain.
Indonesia should 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) amending and implementing laws or other instruments to fully implement 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.
Pakistan
Despite Pakistan’s high-level political commitment to work with the FATF and APG to address its strategic AML/CFT deficiencies, the FATF is not
yet satisfied that Pakistan has made sufficient progress in implementing its action plan, and certain strategic AML/CFT deficiencies remain.
Pakistan failed to provide a satisfactory response to the FATF’s particular concern about the lack of implementation regarding Pakistan’s
terrorist financing offence expressed in June 2011 and its calls upon Pakistan to demonstrate specific action in this regard. Pakistan should
work on implementing its action plan to address these deficiencies, including by (1) demonstrating adequate criminalisation of terrorist financing
and addressing the remaining deficiencies with regard to the criminalisation of money laundering (Special Recommendation II and
Recommendation 1); (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.
Tanzania
Despite Tanzania’s high-level political commitment to work with the FATF and ESAAMLG to address its strategic AML/CFT deficiencies, the FATF
is not yet satisfied that Tanzania has made sufficient progress in implementing its action plan, and certain strategic deficiencies remain.
Tanzania should 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
Despite Thailand’s high-level political commitment to work with the FATF and APG to address its strategic AML/CFT deficiencies, the FATF is not
yet satisfied that Thailand has made sufficient progress in implementing its action plan, and certain strategic deficiencies remain. Thailand
should 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.
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 works with them to address those deficiencies
that pose a risk to the international financial system.
Jurisdictions subject to a FATF call on its members and other jurisdictions to apply counter-measures to protect the international financial
system from the on-going and substantial money laundering and terrorist financing (ML/TF) risks emanating from the jurisdictions*.
Iran
Democratic People's Republic of Korea (DPRK)
Jurisdictions with strategic AML/CFT deficiencies 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**. The FATF calls on its members to consider the risks arising from the
deficiencies associated with each jurisdiction, as described below.
Cuba**
Bolivia
Ethiopia
Kenya
Myanmar
Nigeria
São Tomé and Príncipe
Sri Lanka
Syria
Turkey
* The FATF has previously issued public statements calling for counter-measures on Iran and DPRK. Those statements are updated below.
**Cuba has not engaged with the FATF in the process.
Iran
The FATF, with a renewed urgency, is particularly and exceptionally 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, despite Iran’s engagement with the FATF.
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. Due to the
continuing terrorist financing threat emanating from Iran, jurisdictions should consider the steps already taken and possible additional
safeguards or strengthen existing ones.
The FATF urges Iran to immediately and meaningfully address its AML/CFT deficiencies, in particular by criminalising terrorist financing and
effectively implementing suspicious transactions reporting (STR) requirements. If Iran fails to take concrete steps to improve its CFT regime, the
FATF will consider calling on its members and urging all jurisdictions to strengthen counter-measures in February 2012.
Democratic People's Republic of Korea (DPRK)
The FATF remains concerned by the DPRK’s failure to address the significant deficiencies in its anti-money laundering and combating the
financing of terrorism (AML/CFT) regime and the serious threat this poses to the integrity of the international financial system. The FATF urges
the DPRK to immediately and meaningfully address its AML/CFT deficiencies.
The FATF reaffirms its call on its members and urges all jurisdictions to advise their financial institutions to give special attention to business
relationships and transactions with the DPRK, including DPRK companies and financial institutions. In addition to enhanced scrutiny, the FATF
further calls 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 the DPRK. Jurisdictions should also protect against correspondent
relationships being used to bypass or evade counter-measures and risk mitigation practices, and take into account ML/FT risks when
considering requests by DPRK financial institutions to open branches and subsidiaries in their jurisdiction.
The FATF remains prepared to engage directly in assisting the DPRK to address its AML/CFT deficiencies, including through the FATF
Secretariat.
_________________________________________________________________________________________________________________
Cuba
Cuba has not committed to the AML/CFT international standards, nor has it constructively engaged with the FATF. The FATF has identified Cuba
as having strategic AML/CFT deficiencies that pose a risk to the international financial system. The FATF urges Cuba to develop an AML/CFT
regime in line with international standards, and is ready to work with the Cuban authorities to this end.
_________________________________________________________________________________________________________________
Bolivia
Bolivia has taken steps towards improving its AML/CFT regime, including by enacting new CFT legislation. However, despite Bolivia’s high-level
political commitment to work with the FATF and GAFISUD to address its strategic AML/CFT deficiencies, Bolivia has not made sufficient progress
in implementing its action plan, and certain strategic AML/CFT deficiencies remain. Bolivia should work on addressing these deficiencies
including by: (1) ensuring adequate criminalisation of money laundering (Recommendation 1); (2) adequately criminalising 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.
Ethiopia
Despite Ethiopia’s high-level political commitment to work with the FATF to address its strategic AML/CFT deficiencies, Ethiopia has not made
sufficient progress in implementing its action plan, and certain strategic AML/CFT deficiencies remain. Ethiopia should work on addressing 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.
Kenya
Despite Kenya’s high-level political commitment to work with the FATF and ESAAMLG to address its strategic AML/CFT deficiencies, Kenya has
not made sufficient progress in implementing its action plan, and certain strategic AML/CFT deficiencies remain. Kenya should work on
addressing 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, including by implementing the AML legislation and
setting up its FIU.
Myanmar
Despite Myanmar’s high-level political commitment to work with the FATF and APG to address its strategic AML/CFT deficiencies, Myanmar has
not made sufficient progress in implementing its action plan, and certain strategic AML/CFT deficiencies remain. Myanmar should work on
addressing 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) further 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 (Recommendation 5). The FATF encourages Myanmar to address its remaining deficiencies and continue the
process of implementing its action plan.
Nigeria
Nigeria has taken steps towards improving its AML/CFT regime, including by enacting AML/CFT legislation. However, despite Nigeria’s high-level
political commitment to work with the FATF and GIABA to address its strategic AML/CFT deficiencies, Nigeria has not made sufficient progress in
implementing its action plan, and certain strategic deficiencies remain. Nigeria should work on addressing 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) continuing to
improve the overall supervisory framework for AML/CFT (Recommendation 23). The FATF encourages Nigeria to address its remaining
deficiencies and continue the process of implementing its action plan.
São Tomé and Príncipe
Despite São Tomé and Príncipe’s high-level political commitment to work with the FATF to address its strategic AML/CFT deficiencies, São Tomé
and Príncipe has not made sufficient progress in implementing its action plan, and certain strategic deficiencies remain. São Tomé and Príncipe
should work on addressing 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 a competent authority or competent 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
Sri Lanka has taken steps towards improving its AML/CFT regime, including by enacting AML/CFT amendments. However, despite Sri Lanka’s
high-level political commitment to work with the FATF and APG to address its strategic AML/CFT deficiencies, Sri Lanka has not made sufficient
progress in implementing its action plan, and certain strategic AML/CFT deficiencies remain. Sri Lanka should work on addressing these
deficiencies, including by: (1) adequately criminalising terrorist financing and addressing the remaining deficiencies with regard to the
criminalisation of money laundering (Special Recommendation II and Recommendation 1); 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, including by continuing to work on its AML/CFT legislation.
Syria
Syria has taken significant steps towards improving its AML/CFT regime, including by improving the legal arrangements for freezing terrorist
assets. However, despite Syria’s high-level political commitment to work with the FATF and MENAFATF to address its strategic AML/CFT
deficiencies, Syria has not made sufficient progress in implementing its action plan, and certain strategic AML/CFT deficiencies remain. Syria
should work on addressing its 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) implementing adequate procedures for identifying
and freezing terrorist assets (Special Recommendation III); (3) ensuring that 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) ensuring that
appropriate laws and procedures are in place 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.
Turkey
Turkey has taken steps towards improving its AML/CFT regime, including by submitting CFT legislation to Parliament. Despite Turkey’s high-
level political commitment to work with the FATF to address its strategic AML/CFT deficiencies, Turkey has not made sufficient progress in
implementing its action plan, and certain strategic AML/CFT deficiencies remain. Turkey should work on addressing 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.
As part of its on-going 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. The 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 on-going
basis, that pose a risk to the international financial system. 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.
Algeria
In October 2011, Algeria made a high-level political commitment to work with the FATF and MENAFATF to address its strategic AML/CFT
deficiencies. Algeria has taken steps towards improving its AML/CFT regime. However, the FATF has determined that certain strategic AML/CFT
deficiencies remain. Algeria will work on implementing its action plan to address these deficiencies, including by: (1) adequately criminalising
terrorist financing (Special Recommendations I and II); (2) establishing and implementing an adequate legal framework for identifying, tracing
and freezing terrorist assets (Special Recommendation III), (3) improving and broadening CDD measures and ensuring that they apply to all
financial institutions (Recommendation 5); (4) ensuring a fully operational and effectively functioning Financial Intelligence Unit, in particular
addressing the operational autonomy of the FIU and the authority of the FIU to request and access information (Recommendation 26); and (5)
enacting and implementing appropriate mutual legal assistance legislation (Special Recommendation V). The FATF encourages Algeria to
address its deficiencies and continue the process of implementing its action plan.
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
2011, Angola has taken steps towards improving its AML/CFT regime, including by issuing CDD regulations to banks. However, the FATF has
determined that certain strategic AML/CFT deficiencies remain. Angola 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) ensuring a fully operational and effectively functioning Financial Intelligence Unit (Recommendation 26); and (3)
establishing and implementing an adequate legal framework for identifying, tracing and freezing terrorist assets (Special Recommendation III).
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 2011, Antigua and Barbuda has taken steps towards improving its AML/CFT regime, including by
commencing off-site inspections of its financial institutions. 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); and (2) continuing to
improve the overall supervisory framework (Recommendation 23). The FATF encourages Antigua and Barbuda to address its remaining
deficiencies and continue the process of implementing its action plan.
Argentina
In June 2011, Argentina made a high-level political commitment to work with the FATF to address its strategic AML/CFT deficiencies. Since then,
Argentina has taken steps towards improving its AML/CFT regime, including by addressing some of the concerns the FATF expressed regarding
its June 2011 amendments to its AML legislation, submitting draft CFT legislation to National Congress, issuing a decree dealing with evaluating
effectiveness of its AML/CFT measures; and issuing an FIU Resolution enhancing CDD measures for the financial and foreign exchange sectors.
The FATF has determined that strategic AML/CFT deficiencies remain. Argentina will work on implementing its action plan to address these
deficiencies, including by: (1) adequately criminalising terrorist financing and addressing the remaining deficiencies with regard to the
criminalisation of money laundering (Special Recommendation II and Recommendation 1); (2) establishing and implementing adequate
procedures for the confiscation of funds related to money laundering and identifying and freezing terrorist assets (Recommendation 3 and
Special Recommendation III); (3) enhancing financial transparency (Recommendation 4); (4) ensuring a fully operational and effectively
functioning Financial Intelligence Unit and improving suspicious transaction reporting requirements (Recommendation 13, Special
Recommendation IV and Recommendation 26); (5) implementing an adequate AML/CFT supervisory programme for all financial sectors
(Recommendations 17, 23 and 29); (6) improving and broadening CDD measures for the non-banking or non-foreign exchange sectors
(Recommendation 5); and (7) establishing appropriate channels for international co-operation and ensuring effective implementation
(Recommendation 36, Recommendation 40 and Special Recommendation V). The FATF encourages Argentina 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. Since June 2011, Bangladesh has taken steps towards improving its AML/CFT regime, including by issuing AML/CFT guidance
notes for the insurance sector. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Bangladesh 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); (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
co-operation (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.
Brunei Darussalam
In June 2011, Brunei Darussalam made a high-level political commitment to work with the FATF and APG to address its strategic AML/CFT
deficiencies. Since then, Brunei Darussalam has taken steps towards improving its AML/CFT regime, including by enacting an Anti-Terrorism
Order in July 2011. However, the FATF has determined that strategic AML/CFT deficiencies remain. Brunei Darussalam 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) establishing and implementing adequate procedures for the confiscation of funds related to money
laundering (Recommendation 3); (4) improving suspicious transaction reporting requirements (Recommendation 13 and Special
Recommendation IV); (5) ensuring a fully operational and effectively functioning Financial Intelligence Unit (Recommendation 26); and (6)
enacting and implementing appropriate mutual legal assistance legislation (Recommendation 36 and Special Recommendation V). The FATF
encourages Brunei Darussalam to address its remaining deficiencies and continue the process of implementing its action plan.
Cambodia
In June 2011, Cambodia made a high-level political commitment to work with the FATF and APG to address its strategic AML/CFT deficiencies.
The FATF has determined that strategic AML/CFT deficiencies remain. Cambodia 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) establishing and 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); and (5) establishing and implementing
effective controls for cross-border cash transactions (Special Recommendation IX). The FATF encourages Cambodia 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. The FATF has determined that certain strategic AML/CFT deficiencies remain. Ecuador should continue to work on implementing its
action plan to address these deficiencies, including by: (1) ensuring adequate criminalisation of terrorist financing (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 co-
ordination of financial sector supervision (Recommendation 23). The FATF encourages Ecuador 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. Since that time, Honduras has demonstrated progress in improving its AML/CFT regime, including by adopting legislation that aims
to address issues relating to criminalisation of terrorist financing and freezing of terrorist assets and implementing resolutions that aim to
improve CDD measures. The FATF will conduct an on-site visit to confirm that the process of implementing the required reforms and actions is
underway to address deficiencies previously identified by the FATF.
Kyrgyzstan
In October 2011, Kyrgyzstan made a high-level political commitment to work with the FATF and EAG to address its strategic AML/CFT
deficiencies. Kyrgyzstan has taken steps towards improving its AML/CFT regime. However, the FATF has determined that certain strategic
AML/CFT deficiencies remain. Kyrgyzstan 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 for identifying, tracing and freezing terrorist assets (Special Recommendation III) (3) establishing and
implementing adequate measures for the confiscation of funds related to money laundering (Recommendation 3); (4) establishing effective CDD
measures for all financial institutions (Recommendation 5); and (5) implementing an adequate and effective AML/CFT supervisory programme
for all financial sectors (Recommendation 23). The FATF encourages Kyrgyzstan to address its deficiencies and continue the process of
implementing its action plan.
Mongolia
In June 2011, Mongolia made a high-level political commitment to work with the FATF and APG to address its strategic AML/CFT deficiencies.
The FATF has determined that strategic AML/CFT deficiencies remain. Mongolia 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) establishing adequate procedures for the confiscation of funds related to money laundering (Recommendation 3); (4) establishing
suspicious transaction reporting requirements (Recommendation 13 and Special Recommendation IV); (5) establishing a fully operational and
effectively functioning Financial Intelligence Unit (Recommendation 26); and (6) demonstrating effective regulation of money service providers.
The FATF encourages Mongolia 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 then, Morocco has demonstrated progress in improving its AML/CFT regime, including by adopting amendments to extend
the scope of the money laundering and terrorist financing offences; to broaden customer due diligence requirements and taking steps to
operationalise the Financial Intelligence Unit. 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 adequately criminalising terrorist financing
(Special Recommendation II).
Namibia
In June 2011, Namibia made a high-level political commitment to work with the FATF and ESAAMLG to address its strategic AML/CFT
deficiencies. Namibia has taken steps towards improving its AML/CFT regime, including by securing the information held in the FIU. However,
the FATF has determined that strategic AML/CFT deficiencies remain. Namibia 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); (3) implementing an adequate AML/CFT
supervisory programme with sufficient powers (Recommendation 23 and 29); (4) ensuring a fully operational and effectively functioning
Financial Intelligence Unit, in particular addressing the operational autonomy of the FIU (Recommendation 26); (5) implementing effective,
proportionate and dissuasive sanctions in order to deal with non-compliance with the national AML/CFT requirements (Recommendation 17);
and (6) implementing the 1999 International Convention for the Suppression of Financing of Terrorism (Special Recommendation I). The FATF
encourages Namibia 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 2011, Nepal has taken steps towards improving its AML/CFT regime, including by approving an AML/CFT National Strategy.
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.
Nicaragua
In June 2011, Nicaragua made a high-level political commitment to work with the FATF and CFATF to address its strategic AML/CFT deficiencies.
Since then, Nicaragua has taken steps towards improving its AML/CFT regime, including by establishing an agency responsible for regulating
and supervising the microfinance industry. However, the FATF has determined that strategic AML/CFT deficiencies remain. Nicaragua should
continue to work on implementing its action plan to address these deficiencies, including by: (1) establishing effective CDD measures and
record-keeping requirements, in particular entities not currently regulated by the supervisory authority (Recommendation 5 and
Recommendation 10); (2) establishing adequate STR reporting obligations for ML and FT (Recommendation 13 and Special Recommendation
IV); (3) implementing an adequate AML/CFT supervisory programme for all financial sectors (Recommendation 23); (4) establishing a fully
operational and effectively functioning Financial Intelligence Unit (Recommendation 26); and (5) establishing adequate procedures for
identifying and freezing terrorist assets (Special Recommendation III)The FATF encourages Nicaragua 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 that time, Paraguay has taken steps towards improving its AML/CFT regime, including enacting CFT legislation and issuing
regulations prohibiting anonymous accounts. The FATF will conduct an on-site visit to confirm that the process of implementing the required
reforms and actions is underway to address deficiencies previously identified by the FATF.
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. Since June 2011, the Philippines has taken steps towards improving its AML/CFT regime, including by capacity building in the
areas of supervision and regulation. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. The Philippines
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 and confiscate funds related to money laundering (Special Recommendation III and Recommendation 3); (3) enhancing
financial transparency (Recommendation 4); and (4) extending coverage of reporting entities (Recommendations 12 and 16). The FATF
encourages the Philippines 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 2011, Sudan has taken steps towards improving its AML/CFT regime, including by improving the overall infrastructure
of the FIU and the supervisory framework. 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 that 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.
Tajikistan
In June 2011, Tajikistan made a high-level political commitment to work with the FATF and EAG to address its strategic AML/CFT deficiencies.
The FATF has determined that strategic AML/CFT deficiencies remain. Tajikistan 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 for the confiscation of funds related to money laundering and
identifying and freezing terrorist assets (Recommendation 3 and Special Recommendation III); (3) enhancing financial transparency
(Recommendation 4); (4) ensuring a fully operational, and effectively functioning Financial Intelligence Unit and improving suspicious transaction
reporting requirements (Recommendation 13, Special Recommendation IV, and Recommendation 26); and (5) improving and broadening CDD
measures (Recommendation 5). The FATF encourages Tajikistan 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 2011, Turkmenistan has taken steps towards improving its AML/CFT regime, including by establishing a legal
framework to freeze terrorist assets. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Turkmenistan
should continue to work on implementing its action plan to address these deficiencies, including by: (1) developing collaboration between the
FIU and domestic counterparts, including supervisory authorities; and (2) strengthening international co-operation in the areas of investigation
and confiscation/repatriation of funds. The FATF encourages Turkmenistan 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. Since June 2011, Trinidad and Tobago has taken steps towards improving its AML/CFT regime, including by completing
the registration process of the listed businesses and initiating the supervision of the listed entities. 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); and (2) establishing a fully operational and effectively functioning Financial Intelligence Unit, 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.
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. Since then, Venezuela has taken steps towards improving its AML/CFT regime, including by improving the independence of the FIU
and the regulations for the banking and securities sectors. However, the FATF has determined that certain strategic deficiencies remain.
Venezuela should continue to 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 Recommendations I and 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 FT (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 and APG to address its strategic AML/CFT deficiencies.
The FATF has determined that certain strategic AML/CFT deficiencies remain. Vietnam should continue to work with the FATF and 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) making legal persons subject to criminal liability in line with FATF Recommendation 2 or demonstrating
that there is a constitutional prohibition to prevent this; (4) improving the overall supervisory framework (Recommendation 23); (5) improving
and broadening customer due diligence measures and reporting requirements (Recommendation 5, 13, and Special Recommendation IV); and
(6) strengthening international co-operation (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 MENAFATF to address its strategic AML/CFT
deficiencies. 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) establishing and implementing adequate procedures to identify and freeze terrorist assets
(Special Recommendation III); (2) conducting outreach to sensitise reporting institutions of their AML/CFT obligations (Recommendation 25); (3)
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 (4) 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.
Zimbabwe
In June 2011, Zimbabwe made a high-level political commitment to work with the FATF and ESAAMLG to address its strategic AML/CFT
deficiencies. The FATF has determined that strategic AML/CFT deficiencies remain. Zimbabwe should continue to work on implementing its
action plan to address these deficiencies, including by: (1) adequately criminalising money laundering and terrorist financing (Recommendation I
and 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) ensuring
that 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); (5) enacting and implementing appropriate mutual legal assistance legislation (Special
Recommendation V); and (6) implementing the 1999 International Convention for the Suppression of Financing of Terrorism (Special
Recommendation I). The FATF encourages Zimbabwe to address its remaining deficiencies and continue the process of implementing its action
plan.
The following Country is no longer subject to FATF’s monitoring process under its on-going global AML/CFT compliance
process.
Ukraine
The FATF welcomes Ukraine’s significant progress in improving its AML/CFT regime and notes that Ukraine has largely met its commitments in
its Action Plan regarding the strategic deficiencies that the FATF had identified in February 2010. Ukraine is therefore no longer subject to FATF’
s monitoring process under its on-going global AML/CFT compliance process. Ukraine will work with MONEYVAL as it continues to address the
full range of AML/CFT issues identified in its Mutual Evaluation Report, and further strengthen its AML/CFT regime.
Jurisdiction not making sufficient progress
The FATF is not yet satisfied that the following jurisdictions have made sufficient progress on their action plan agreed upon with the FATF. The
most significant action plan items and/or the majority of the action plan items have not been addressed. If these jurisdictions do not take
sufficient action to implement significant components of their action plan by February 2012, then the FATF will identify these jurisdictions as
being out of compliance with their agreed action plans and will take the additional step of calling upon its members to consider the risks arising
from the deficiencies associated with the jurisdiction.
Ghana
Despite Ghana’s high-level political commitment to work with the FATF and GIABA to address its strategic AML/CFT deficiencies, the FATF is not
yet satisfied that Ghana has made sufficient progress in implementing its action plan, and certain strategic AML/CFT deficiencies remain. Ghana
should work with the FATF and GIABA 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.
Indonesia
Despite Indonesia’s high-level political commitment to work with the FATF and APG to address its strategic AML/CFT deficiencies, the FATF is
not yet satisfied that Indonesia has made sufficient progress in implementing its action plan, and certain strategic AML/CFT deficiencies remain.
Indonesia should 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) amending and implementing laws or other instruments to fully implement 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.
Pakistan
Despite Pakistan’s high-level political commitment to work with the FATF and APG to address its strategic AML/CFT deficiencies, the FATF is not
yet satisfied that Pakistan has made sufficient progress in implementing its action plan, and certain strategic AML/CFT deficiencies remain.
Pakistan failed to provide a satisfactory response to the FATF’s particular concern about the lack of implementation regarding Pakistan’s
terrorist financing offence expressed in June 2011 and its calls upon Pakistan to demonstrate specific action in this regard. Pakistan should
work on implementing its action plan to address these deficiencies, including by (1) demonstrating adequate criminalisation of terrorist financing
and addressing the remaining deficiencies with regard to the criminalisation of money laundering (Special Recommendation II and
Recommendation 1); (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.
Tanzania
Despite Tanzania’s high-level political commitment to work with the FATF and ESAAMLG to address its strategic AML/CFT deficiencies, the FATF
is not yet satisfied that Tanzania has made sufficient progress in implementing its action plan, and certain strategic deficiencies remain.
Tanzania should 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
Despite Thailand’s high-level political commitment to work with the FATF and APG to address its strategic AML/CFT deficiencies, the FATF is not
yet satisfied that Thailand has made sufficient progress in implementing its action plan, and certain strategic deficiencies remain. Thailand
should 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.
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