The FIAU would like to bring to your attention the latest FATF ‘High-Risk Jurisdictions subject to a Call for Action’ (previously known as ‘Public Statement’) and ‘Jurisdictions under Increased Monitoring‘ (previously known as ‘Improving global AML/CFT compliance: on-going process’) documents issued by the FATF on 21 October 2022. A copy of these documents has been uploaded on the FIAU’s website under ‘Country Statements’.
The FATF classifies the jurisdictions included in these documents into different categories, in accordance with the deficiencies present in such jurisdictions, and the level of commitment and progress made in addressing such deficiencies.
The categories are the following:
- Jurisdictions with strategic deficiencies in their regime to counter money laundering, terrorist financing, and financing of proliferation that have failed to meaningfully address their AML/CFT deficiencies and are subject to a call for counter-measures (listed under ‘High-Risk Jurisdictions subject to a Call for Action’). This process is informally referred to as ‘’black listing’’;
- Jurisdictions that have developed an action plan with the FATF and have made a high-level political commitment to address their AML/CFT deficiencies (listed in the ‘Jurisdictions under Increased Monitoring’). This process is informally referred to as “grey listing”. This document also lists jurisdictions that are no longer subject to the FATF on-going global AML/CFT compliance process, where applicable.
Subject persons are required to implement the measures set out under Regulation 11 of the Prevention of Money Laundering and Funding of Terrorism Regulation S.L. 373.01 (“PMLFTR”) and under Chapter 8 of the FIAU Implementing Procedures Part I, which is legally binding upon all subject persons in terms of Regulation 17 of the PMLFTR.
High-Risk Jurisdictions subject to a Call for Action
Since February 2020, in light of the COVID-19 pandemic, the FATF has paused the review process for Iran and DPRK, given that they are already subject to the FATF’s call for countermeasures. Therefore, reference should be made to the statement on these jurisdictions adopted in 21 February 2020. While the statement may not necessarily reflect the most recent status of Iran and the Democratic People’s Republic of Korea’s AML/CFT regimes, the FATF’s call to apply countermeasures on these high-risk jurisdictions remains in effect. In October 2022, the FATF added Myanamar to the list of jurisdictions subject to a call for action. Subject persons should refer to Regulation 11(11) of the PMLFTR and apply the enhanced due diligence measures therein to the above-mentioned jurisdictions.
Jurisdictions under Increased Monitoring
Since the start of the COVID-19 pandemic, the FATF has provided some flexibility to jurisdictions not facing immediate deadlines to report progress on a voluntary basis.
The following countries had their progress reviewed by the FATF since June 2022: Albania, Barbados, Burkina Faso, Cambodia, Cayman Islands, Haiti, Jamaica, Jordan, Mali, Morocco, Myanmar, Nicaragua, Pakistan, Panama, Philippines, Senegal, South Sudan, Türkiye, UAE, and Uganda. Gibraltar chose to defer reporting; thus, the statement issued in June 2022 for that jurisdiction may not necessarily reflect the most recent status of the jurisdiction’s AML/CFT regime. Following review, the FATF now also identifies the Democratic Republic of the Congo, Mozambique, and Tanzania. With regards to the enhanced due diligence measures to be applied to the above-mentioned jurisdictions, subject persons should refer to Regulation 11(10) of the PMLFTR.
Jurisdictions no longer subject to increased monitoring
Nicaragua and Pakistan are no longer subject to increased monitoring.
If any further information is required, you may contact the FIAU on [email protected]