FinCEN Updates List of Jurisdictions with AML/CFT Deficiencies

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On March 16, the Financial Crimes Enforcement Network (FinCEN) issued an advisory announcing that the Financial Action Task Force (FATF) has updated its list of jurisdictions that have strategic deficiencies in their anti-money laundering (AML) and counter-terrorist financing (CFT) regimes. 

Specifically, FATF has noted that: (1) Indonesia has been removed from FAFT’s list that calls for enhanced due diligence and has been moved to the FATF’s list of jurisdictions having AML/CFT deficiencies, and (2) Albania, Cambodia, Kuwait, Namibia, Nicaragua, Pakistan and Zimbabwe have been removed from the FATF listing and monitoring process. 

These changes may affect US financial institutions’ obligations and risk-based approaches with respect to the relevant jurisdictions. National Futures Association (NFA) has issued a notice reminding futures commission merchants and introducing brokers to review the FinCEN advisory to ensure that their AML programs have the most current information on FATF-identified jurisdictions with AML/CFT deficiencies, and revise their AML programs accordingly. 

The FinCEN Advisory is available here

The NFA Notice to Members is available here.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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