29th October 2024
The FIAU would like to bring to your attention the latest FATF ‘High-Risk Jurisdictions subject to a Call for Action’ and ‘Jurisdictions under Increased Monitoring’ documents issued by the FATF on the 25 of October 2024. 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, according to the deficiencies present in the listed 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 countermeasures (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
Iran and the Democratic People’s Republic of Korea (DPRK) remain in the list of high-risk jurisdictions subject to a call for action. The FATF reiterated its concerns over the DPRK’s continued failure to address the significant deficiencies in its AML/CFT regime and the serious threats posed by the DPRK’s illicit activities related to the proliferation of weapons of mass destruction and its financing. In particular, the FATF notes that the DPRK has increased connectivity with the international financial system, which raises proliferation financing risks. Therefore, the FATF calls for greater vigilance and renewed implementation and enforcement of countermeasures against the DPRK.
Since 2020, Iran has submitted reports to the FATF in January and August 2024 which reflected no material changes in the status of its action plan. The FATF’s call to apply countermeasures on these high-risk jurisdictions remains in effect.
In October 2022, the FATF added Myanmar to the list of jurisdictions subject to a call for action until its full action plan is completed. If no further progress is made by February 2025, the FATF will consider countermeasures.
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
The following countries had their progress reviewed by the FATF since June 2024: Bulgaria; Burkina Faso, Cameroon, Croatia, Democratic Republic of Congo, Mali, Mozambique, Namibia; Nigeria, Philippines, Senegal, South Africa, South Sudan, Tanzania, Vietnam, and Yemen. Haiti, Kenya, Monaco, Syria and Venezuela chose to defer reporting; thus, the statements issued previously for those jurisdictions are applicable, but it may not necessarily reflect the most recent status of the jurisdictions’ AML/CFT regimes. Following review, the FATF now also identifies Algeria, Angola, Côte d’Ivoire and Lebanon.
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 by the FATF
Senegal is no longer under increased monitoring by the FATF.
A more detailed summary of the outcomes of the FATF Plenary which took place between 23 – 25 October 2024 can be accessed from the following link.
Membership Issues
The suspension of the Russian Federation’s membership remains in effect.
Furthermore, the FATF emphasised that the statements it has published since March 2022 are still valid and must be upheld. The FATF urges all jurisdictions to be vigilant with regards to current and emerging risks of the countermeasures in place being circumvented, to ensure that the international financial system is protected.
If any further information is required, you may contact the FIAU on [email protected]