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FinCEN Advisory FIN-2020-A004

July 21st | 2020



The Financial Crimes Enforcement Network (FinCEN) recently issued an advisory to inform financial institutions of updates to the Financial Action Task Force (FATF) list of jurisdictions with strategic anti-money laundering and combating the financing of terrorism (AML/CFT) and counter-proliferation financing deficiencies.


In particular, the advisory references FATF’s February 2020 “High-Risk Jurisdictions Subject to a Call for Action”, which called for countermeasures on Iran and the Democratic People’s Republic of Korea (DPRK). Because of COVID-19, FATF temporarily paused its review process for most countries with strategic deficiencies earlier this year. This advisory notes that although Iceland and Mongolia have substantially completed their action plans to address strategic AML/CFT deficiencies, both countries are still “Jurisdictions under Increased Monitoring” until the FATF can conduct on-site visits to verify that each country has begun implementing its reforms.


FinCEN also advises that U.S. financial institutions consider in their due diligence obligations for Foreign Financial Institutions (FFI) in addition to other rules, the AML/CFT deficiencies with several other jurisdictions including Albania, The Bahamas, Barbados, Botswana, Burma (Myanmar), Cambodia, Ghana, Iceland, Jamaica, Mauritius, Mongolia, Nicaragua, Pakistan, Panama, Syria, Uganda, Yemen, and Zimbabwe.

Financial firms should be sure to review the entire advisory here.

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