Who’s on the FATF’s naughty step?

So the FATF’s latest take on their list of naughty countries – or, more properly, those jurisdictions with strategic AML/CFT deficiencies – is out.  Their latest plenary meeting, this time in Busan in Korea, ended on 24 June 2016, and the outcomes were issued immediately.  North Korea is still so far back on the naughty step that it is practically in the understair cupboard, but the FATF has taken note of Iran’s high-level commitment to an AML action plan and as a reward “has suspended counter-measures for twelve months”.  In practical terms for the MLRO this makes little difference: Iran is still on the list, albeit in a slightly different position, and therefore all business connected to it is still subject to enhanced due diligence.

As for the rest of the list, there are some changes.  Two countries – Myanmar and Papua New Guinea – have done enough to work themselves off the list, which means that business connected with them does not have to be subject to EDD (although many MLROs will prefer to keep it that way for now – as always, you can go beyond the requirements of the list if you wish).  There are no new entrants to the list, although that surprises me: I was certain that Panama, having only just worked its way off the list in February 2016, would make a star reappearance, but no.  Papers notwithstanding, Panama is not on the FATF’s list.  So who is?  Here we go: Afghanistan, Bosnia and Herzegovina, Guyana, Iraq, Laos, Syria, Uganda, Vanuatu and Yemen.  None of these seems to be in the last chance saloon – i.e. in danger of falling subject to counter-measures – but the FATF has been overtaken by events in that it admits that, owing to security concerns, it has been unable to do an onsite visit to verify progress in either Syria or Yemen.  I don’t blame them: I’d do a lot for AML, but I’m not sure about tiptoeing through a war zone to ask about due diligence documents and record-keeping.

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