FATF: Updated list of high-risk or monitored jurisdictions

26/06/2023
The FATF has updated the list of high-risk jurisdictions and other monitored jurisdictions as follows:
  • Jurisdictions added: Cameroon, Croatia, Nigeria and Vietnam,
  • Jurisdictions removed from the list: Afghanistan, Cambodia, Morocco, Nicaragua, Pakistan, Trinidad and Tobago, Vanuatu and Zimbabwe.

As a reminder, a jurisdiction under enhanced scrutiny undertakes to implement a rapid action plan to resolve any shortcomings.We review the status for some selected jurisdictions below:


Vietnam:
Although it adopted a Mutual Evaluation Report (MER) in November 2021, having made progress in implementing the recommendations, (including joining the ARIN-AP inter-institutional network and adopting a national action plan on AML/CFT/CPF), Vietnam still needs to focus on various other issues:
  1. Improve risk understanding, national coordination and cooperation in the fight against money laundering and terrorist financing.
  2. Strengthen international cooperation.
  3. Implement effective risk-based supervision of financial institutions (FIs) and designated non-financial entities and persons (DNFBPs).
  4. Regulate virtual assets and virtual asset service providers.
  5. Address technical compliance gaps such as money laundering offences, targeted financial sanctions, customer due diligence and suspicious transaction reporting.
  6. Conduct awareness-raising activities with the private sector.
  7. Implement a regime that provides the competent authorities with accurate, timely and adequate beneficial ownership information.
  8. Ensure the independence of the Financial Intelligence Unit (FIU) and improve the quality and quantity of financial intelligence analysis and dissemination.
  9. Prioritise parallel financial investigations and increase the number of money laundering investigations and prosecutions.
  10. Ensure the supervision of financial institutions and designated non-financial entities and persons to ensure compliance with obligations relating to the prevention of terrorist financing and to avoid circumvention.


At this Plenary in June 2023, the FATF also considered that certain jurisdictions merited an on-site assessment to verify the ongoing implementation of anti-money laundering and combating the financing of terrorism (AML/CFT) reforms, as well as the maintenance of the necessary political commitment to pursue future implementation. This is the case for the Cayman Islands and Panama.

Other jurisdictions are encouraged to continue their efforts, such as South Africa and Gibraltar.
Find a more detailed review of these jurisdictions:


Cayman Islands:
Placed on a strengthened list since February 2021, the Cayman Islands have undertaken a number of reforms including:
  1. Application of effective, proportionate and dissuasive sanctions, including administrative sanctions and enforcement measures against obligated entities, to ensure prompt and effective correction of breaches.
  2. Imposition of appropriate and effective sanctions where relevant parties, including legal persons, do not provide accurate, adequate and up-to-date information on beneficial owners.
  3. Demonstrate the ability to provide accurate, proportionate and up-to-date information on beneficial owners.
  4. Prosecution of all types of money laundering according to the risk profile of the jurisdiction and application of dissuasive, effective and proportionate sanctions in such cases.

Panama:
Placed on a strengthened list since June 2019, Panama has undertaken numerous reforms including:
  1. Strengthening its understanding of national and sectoral money laundering and terrorist financing risks, and using this information to guide its national policies to mitigate these risks.
  2. Taking steps to identify unlicensed remitters, implementing a risk-based approach to supervising the Non-Financial Persons and Entities (NFP) sector, and applying effective, proportionate and dissuasive sanctions for violations of anti-money laundering and anti-terrorist financing laws.
  3. Verification of the updating of beneficial owner information by Obligated Entities, establishment of mechanisms to monitor the activities of offshore entities, assessment of existing risks of misuse of legal persons and arrangements to put in place specific measures to prevent the misuse of nominee shareholders and directors, and ensuring prompt access to adequate and accurate beneficial owner information.
  4. Using the proceeds of the Criminal Financial Report (CFR) to investigate money laundering, demonstrating its ability to investigate and prosecute money laundering related to foreign tax offences, cooperating constructively and in a timely manner internationally in such cases, and maintaining a focus on money laundering investigations in high risk areas identified in the National Mutual Evaluation Report (NME) and Mutual Review Report (MRR).

South Africa:
Under review since February 2023, South Africa has taken steps to improve its AML/CFT regime, in particular by strengthening the criminalisation of terrorist financing.
South Africa must continue to implement its action plan with a view to a new assessment.


Gibraltar:
Gibraltar has been on the enhanced list since June 2022 and has taken steps to strengthen the effectiveness of its AML/CFT regime. As the deadlines have expired, the FATF encourages Gibraltar to continue implementing its action plan to address its strategic deficiencies as soon as possible, including by demonstrating that it is able to obtain more final confiscation orders that are proportionate to the risk and context.



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