It may be recalled that the Financial Action Task Force (FATF) used to maintain a list of ‘Non-Cooperative Countries and Territories’ – a total of 23 countries/territories appeared on the list at one time or another. As and when a listed entrant made significant progress in addressing AML/CFT deficiencies it was removed from the list; the last country was removed in October 2006.

In April of last year the G20 Leaders asked FATF to ‘revise and reinvigorate’ the review process for assessing compliance by jurisdictions with AML/CFT standards.

In response, FATF has produced not one but two documents.

The first one is a ‘Public Statement’ which identifies those jurisdictions with such deficiencies, ranging from the likes of Pakistan, where some effort has been made, to Iran where FATF will consider calling for a strengthening of counter-measures in June of this year if no steps are taken by that country to improve its AML/CFT regime. Paul Vlaanderen, FATF president, stressed that this is not simply a ‘one-off’ blacklist but rather ‘an evolving product’ with countries leaving the list and countries entering the list as the review process progresses.

The second document contains a list of jurisdictions ranging from Greece to Qatar where there are also deficiencies but where FATF has been provided with a written high-level political commitment to address the identified deficiencies.

Firms will need to bear in mind these lists when considering, and providing internal reports on, their AML/CFT obligations.

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