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US Banks Face New AML/CTF Challenges as FATF Updates Jurisdictional Lists

The Financial Crimes Enforcement Network (FinCEN) has issued a warning to US financial institutions regarding the growing risks of money laundering, terrorist financing, and proliferation financing emanating from certain jurisdictions. This move comes after the Financial Action Task Force (FATF), an international body responsible for setting anti-money laundering standards, updated its lists of countries with strategic deficiencies in their anti-money laundering and combating the financing of terrorism regimes.

DPRK and Iran Remain High-Risk Jurisdictions

The FATF has reiterated its concerns over the Democratic People’s Republic of Korea (DPRK) and Iran’s failure to address significant deficiencies in their AML/CTF regimes. The two countries have been subject to FATF countermeasures, which require US financial institutions to apply enhanced due diligence when dealing with them. In addition, US persons are prohibited from engaging in transactions or dealings with Iranian financial institutions.

Venezuela and Monaco Added to Increased Monitoring List

The FATF has added Venezuela and Monaco to its list of jurisdictions under increased monitoring, citing concerns over their AML/CTF regimes. The move is intended to encourage these countries to address their deficiencies and improve their anti-money laundering and combating the financing of terrorism frameworks.

US Financial Institutions Must Comply with Enhanced Due Diligence Obligations

FinCEN has reminded US financial institutions that they must apply enhanced due diligence when dealing with correspondent accounts for foreign banks operating in countries designated by the FATF as non-cooperative with respect to international anti-money laundering principles. The move is intended to reduce the risk of money laundering and terrorist financing.

Burma Remains on High-Risk List

The FATF has kept Burma on its list of high-risk jurisdictions, urging other countries to apply enhanced due diligence when dealing with correspondent accounts for Burmese banks. FinCEN advises US financial institutions to continue applying enhanced due diligence when engaging in financial transactions with Burma.

US Financial Institutions Must File Suspicious Activity Reports

If a US financial institution knows or suspects that a transaction involves funds derived from illegal activity, it must file a Suspicious Activity Report (SAR) with FinCEN. The move is intended to help law enforcement agencies identify and disrupt money laundering and terrorist financing schemes.

Questions and Comments

FinCEN invites questions and comments regarding the contents of this release and can be addressed to the Regulatory Support Section at frc@fincen.gov.