The Financial Action Task Force (FATF) released two documents, indicating jurisdictions with strategic deficiencies in their anti-money laundering and combating the financing of terrorism (AML/CFT) regimes.
High-risk jurisdictions have significant strategic deficiencies in their regimes to counter money laundering, terrorist financing, and financing of proliferation. For all countries identified as high-risk, the FATF calls on all members and urges all jurisdictions to apply enhanced due diligence, and, in the most serious cases, countries are called upon to apply counter-measures to protect the international financial system from the money laundering, terrorist financing, and proliferation financing (ML/TF/PF) risks emanating from the country. This list is often externally referred to as the “black list”. Since February 2020, in light of the COVID-19 pandemic, the FATF has paused the review process for countries in the list of High-Risk Jurisdictions subject to a Call for Action, given that they are already subject to the FATF’s call for countermeasures. Therefore, please refer to the statement on these jurisdictions adopted in 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 for action on these high-risk jurisdictions remains in effect.
In February 2020, the FATF issued a renewed public statement calling for countermeasures to be applied to Iran, due to the country’s insufficient progress in addressing serious deficiencies in its AML/CFT regime. In its plenary meeting of October 2021, the FATF has confirmed that the February 2020 call for action on Iran remains in effect. The FATF is particularly concerned about Iran's high risk of terrorist financing and the threatening impact thereof on the international financial system.
Against this background, DNB and the Ministry of Finance urge financial institutions to continue to comply with the tighter measures with respect to transactions and business relationships in connection with Iran. This could include, for example, ex ante collection of additional information about the purpose and intended nature of the transactions or business relationships, enhanced monitoring by increasing the number of checks performed on transactions and business relationships, and selecting transaction patterns for further investigation.
DNB and the Ministry of Finance also reiterate the need to promptly report all unusual transactions with Iran to FIU-NL. Institutions must consider geographic risk factors when establishing whether transactions qualify as unusual based on the subjective indicator. This also includes the involvement in transactions of parties from countries without effective AML/CFT systems, such as Iran.
The FATF continues to be concerned about North Korea's serious deficiencies in addressing money laundering and terrorist financing, and the serious threat this poses to the integrity of the international financial system. The FATF is also highly concerned about the threat from North Korea's nuclear proliferation and proliferation funding. DNB and the Ministry of Finance emphasize that institutions must comply with the tighter measures regarding business relationships with North Korean residents and transactions to/from this country, also with a view to the restrictions following from the UN and EU sanctions.
The document “Jurisdictions under Increased Monitoring” lists the countries that have serious deficiencies in their AML/CFT systems but have expressed their commitment to address these. This list includes the following jurisdictions:
Malta is no longer subject to increased monitoring.
Financial institutions must take the specific circumstances regarding these countries into account when taking AML/CFT measures
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