FinCEN Updates List of Deficient Countries July 2020

On July 14, 2020, FinCEN released an advisory on the FATF-identified jurisdictions with AML/CFT deficiencies.   This advisory, known as FIN-2020-A004, relays information to US financial institutions regarding countries the Financial Action Task Force (FATF) has identified as having deficiencies.  

FATF is an intergovernmental body comprised of 37 nations that work together to create uniform anti-money laundering standards.  When countries don’t meet their standards, FATF communicates deficient countries to the FinCEN, who then provides communication to financial institutions.

This current advisory noted that FATF has temporarily paused its review process for most countries with strategic deficiencies due tot he COVID-19 pandemic. In their advisory, FinCEN explains that FATF made the initial determination that Iceland and Mongolia have substantially completed their action plans, but will remian identified as “Jurisdictions under Increased Monitoring” until the FATF can conduct on-site visits to verify that each country has begun implementing its reforms.  Therefore, the current list of Sanction II countries includes The Bahamas, Barbados, Botswana, Burma (Myanmar), Cambodia, Ghana, Iceland, Jamaica, Mauritius, Mongolia, Nicaragua, Pakistan, Panama, Syria, Uganda, Yemen, and Zimbabwe.

The Sanction I countries of Iran (requiring enhanced due diligence) and the Democratic People’s Republic of Korea (which requires countermeasures) remain unchanged since FATF’s February 2020 guidance.

The full advisory can be found here.

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