The Financial Crimes Enforcement Network (“FinCEN”), an agency within the U.S. Treasury Department, has put forth an Advisory on the FATFIdentified Jurisdictions with AML/CFT (Anti-Money Laundering/Combating the Financing of Terrorism) Deficiencies. This advisory concerns the impact of the October 2016 Financial Action Task Force (“FATF”) update to its list of jurisdictions with AML/CFT deficiencies.

FATF designates two categories of countries with AML/CFT deficiencies: FinCEN Section I is comprised of jurisdictions for which all countries should either enact countermeasures or conduct Enhanced Due Diligence (“EDD”) to guard against potential risks; Section II is comprised of jurisdictions that are of concern, but have developed an Action Plan with FATF.