Financial Crime World

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Myanmar’s Blacklisting by the Financial Action Task Force: Implications for Businesses and Compliance Risk Increased

The Financial Action Task Force (FATF) has added Myanmar to its blacklist of high-risk jurisdictions, joining Iran and North Korea. This move is a result of Myanmar’s significant strategic deficiencies in its regimes to counter money laundering, terrorist financing, and the financing of proliferation.

Myanmar’s Background and Reasons for Blacklisting

Myanmar was placed on FATF’s greylist in February 2020 due to numerous money laundering and terrorist financing vulnerabilities. The country was required to implement an action plan to strengthen its anti-money laundering (AML) and combating the financing of terrorism (CFT) regime.

However, despite warnings from FATF in June 2022 for Myanmar to quickly comply with the action plan, the country failed to make sufficient progress. As a result, FATF downgraded Myanmar to its blacklist, indicating that it will remain on the list until it completes the full action plan for addressing its AML/CFT deficiencies.

Impact on Companies Doing Business in Myanmar

The blacklisting of Myanmar by FATF increases compliance risks for companies investing or doing business in the country. As a result, companies operating in Myanmar or financial institutions processing payments with possible links to Myanmar should promptly review and consider whether risk-based updates to their existing compliance programs are necessary.

Companies operating in Myanmar or financial organizations handling transactions related to Myanmar need to:

  • Assess the level of exposure to potential risks associated with Myanmar.
  • Update existing anti-money laundering (AML) and combating financing terrorism (CFT) compliance programs to reflect enhanced due diligence.
  • Monitor and report any suspicious activities or transactions that may indicate money laundering, terrorist financing, or other illicit practices.

Expert Assistance

Clifford Chance has experts on internal compliance as well as export controls and sanctions who can assist businesses navigate this procedure. For more information, please contact:

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