by Matt Rizzo
June 26, 2023
In our article on the Financial Action Task Force (FATF), we explained the important role that this inter-governmental organisation has in the world-wide fight against money laundering and terrorist financing. We highlighted the importance of tracking updates published by the FATF, and how changes to the list of high-risk countries maintained by the FATF may mandate changes to the type of due diligence you apply to your clients.
The FATF maintains two lists of high-risk countries – a “blacklist” and a “grey list”. The blacklist, officially known as “High-Risk Jurisdictions Subject to a Call for Action” includes countries that are considered to be non-cooperative in the global fight against money laundering and terrorist financing. The “grey list”, officially known as “Jurisdictions under Increased Monitoring” includes countries that are identified by the FATF to have strategic deficiencies in their AML/CFT regimes but are making significant efforts to improve and are working with the FATF to resolve these issues within the agreed timeframes.
These lists are usually updated every four months at the end of the FATF’s plenary session, a meeting open to delegations from all 200+ FATF member countries.
Following last Friday’s plenary session, the FATF has updated the list of high-risk countries as explained in more detail below.
The following countries were added to the list of Jurisdictions under increased monitoring also known as the grey list:
FATF Blacklist
FATF Greylist
Cameroon is the latest of eleven African country to be placed by the FATF on the list of Other Monitored Jurisdictions, joining Nigeria and South Africa, which were added to the grey list last February. The FATF expects Cameroon to improve its AML regime, including the implementation of effective risk-based supervision on non-bank financial institutions, as well as the Designated Non-Financial Businesses and Professions (DNFBPs).
Croatia is the only European Union country on the FATF list. The FATF noted the progress made following the MER in December 2021 but highlighted a number of areas that need improvement, including tackling the misuse of legal persons and arrangements and the use of cash in real estate transactions.
The third country to be added to the grey list in June 2023 is Vietnam, with the FATF action plan including effective risk-based supervision of both financial institutions as well as DNFBPs. These organisations and their supervisors are also expected to ensure that sanctions are being adhered to.
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