The Financial Action Task Force (FATF) is an inter-governmental body established to promote effective anti-money laundering and counter-terrorism financing (AML/CFT) systems worldwide.
The FATF has developed a series of Recommendations that are recognised as the international standard for combating money laundering and the financing of terrorism.
Improving Global AML/CFT Compliance is seen as on ongoing process, and the FATF monitors the progress of its members in implementing necessary measures, periodically reporting on the progress made.
A number of countries such as Ethiopia, Sri Lanka and Tunisia have significantly strengthened their AML/CFT regimes, addressing all deficiencies identified by the FATF and therefore no longer being subject to the FATF’s on-going compliance monitoring.
In October 2019 the FATF identified jurisdictions that still have strategic AML/CFT deficiencies for which they have developed an action plan with the FATF.
Which countries need to improve their AML/CFT compliance, and how?
Each of the following jurisdictions has provided a written high-level political commitment to work with the FATF to address the identified deficiencies. These agreements were entered into between 2010 and 2019, depending on the jurisdiction, and the FATF will continue to report on the progress made.
The Bahamas
Date first entered into agreement: October 2018
Steps taken towards improving AML/CFT regime
- Instituting a protocol and case management system to further enhance international cooperation
- Initiating risk-based supervision of non-bank financial institutions
- Further implementing the recent Beneficial Ownership Law
Areas for further improvement
- Ensuring that authorities are investigating and prosecuting all types of money laundering
- Increasing the identification, tracing and freezing or restraining of assets
Botswana
Date first entered into agreement: October 2018
Steps taken towards improving AML/CFT regime
- Adopting risk-based AML/CFT supervisory manuals for financial sector supervisors
- Implementing an electronic STR filing system among financial institutions (FIs) and certain types of Designated Non-Financial Business and Professions (DNFBPs)
Areas for further improvement
- Conducting comprehensive risk assessments and implementing a risk-based AML/CFT strategy
- Improving its analysis and dissemination of financial intelligence by the financial intelligence unit (FIU), and enhancing the use of financial intelligence among the relevant law enforcement agencies (LEAs)
- Developing and implementing CFT strategy, and ensuring the terrorism financing (TF) investigation capacity of LEAs
- Implementation of targeted financial sanctions measures related to terrorist financing and proliferation financing (PF)
Cambodia
Date first entered into agreement: February 2019
Steps taken towards improving AML/CFT regime
- Initiating off-site and on-site supervision of the real estate and casino sectors
Areas for further improvement
- Implementing risk-based supervision to banks
- Increasing its FIU resource, enhancing its analysis of STRs and increasing disseminations to LEAs
- Increasing money laundering (ML) investigations and prosecutions through enhanced cooperation and provision of targeted training to all LEAs
- Increasing freezing and confiscation of criminal proceeds
- Establishing the legal framework to implement UN sanctions
Ghana
Date first entered into agreement: October 2018
Steps taken towards improving AML/CFT regime
- Conducting a risk assessment on legal persons
- Developing a framework for adequate and effective investigation and prosecution of TF
Areas for further improvement
- Implementing a comprehensive risk-based national AML/CFT Policy
- Improving risk-based supervision, by enhancing the capacity of the regulators and the awareness of the private sector
- Ensuring the timely access to adequate, accurate and current basic and beneficial ownership information
Iceland
Date first entered into agreement: October 2019
Steps taken towards improving AML/CFT regime
- Carrying out a second national risk assessment
- Comprehensive outreach to deepen the understanding of relevant risks across sectors
- Enhancing risk based supervision and strengthening capacities of investigation and law enforcement authorities
Areas for further improvement
- Ensuring access to accurate basic and beneficial ownership information
- Introducing an automated system for suspicious transaction report (STR) filing and enhancing the FIU’s analytical capacity
- Implementation of targeted financial sanctions (TFS)
Mongolia
Date first entered into agreement: October 2019
Steps taken towards improving AML/CFT regime
- Enhancing its ML and TF risk understanding
- Introducing a comprehensive framework to counter PF
- Enhancing TF legal framework
Areas for further improvement
- Applying a risk-based approach to supervision including TFS for breaches of AML/CFT obligations
- Demonstrating increased investigations and prosecutions of different types of ML activity in line with identified risks
- Demonstrating cooperation and coordination between authorities to prevent sanctions evasion
Pakistan
Date first entered into agreement: June 2018
Steps taken towards improving AML/CFT regime
- Recent development of its ML/TF risk assessment
- Reiteration of its political commitment to completing its action plan and implementing AML/CFT reforms at October 2019 plenary
Areas for further improvement
- Adequately demonstrating its proper understanding of TF risks and efforts by LEAs to identify, investigate and prosecute target designated persons and entities
- Demonstrating that effective remedial actions and sanctions are applied in cases of AML/CFT violations
- Demonstrating that authorities are cooperating and taking action to combat illegal money or value transfer services (MVTS) and cash couriers
- Demonstrating effective implementation of TFS and enforcement against violations
- Demonstrating that facilities and services owned or controlled by designated persons are deprived of their resources
Panama
Date first entered into agreement: June 2019
Steps taken towards improving AML/CFT regime
- Drafting sectoral risk assessments for the corporate and DNFBP sectors and free trade zones
Areas for further improvement
- Strengthening its understanding of the national and sectoral ML/TF risk and informing findings to its national policies to mitigate the identified risks
- Proactively taking action to identify unlicensed money remitters, applying a risk-based approach to supervision of the DNFBP sector and implementing sanctions again AML/CFT violations
- Ensuring adequate verification and updating of beneficial ownership information by obliged entities
- Ensuring effective use of FIU products for ML investigations
Syria
Date first entered into agreement: February 2010
Steps taken towards improving AML/CFT regime
- Criminalising terrorist financing and establishing procedures for freezing terrorist assets
Areas for further improvement
- While the FATF determined that Syria has completed its agreed action plan, due to the security situation, the FATF has been unable to conduct an on-site visit
Trinidad and Tobago
Date first entered into agreement: February 2010
Steps taken towards improving AML/CFT regime
- Adopting and implementing the relevant measures to enhance international cooperation
- Addressing measures for transparency and beneficial ownership
- Completing the legislative efforts to enhance the processing of ML charges before the courts
- Taking measures to enhance tracing and confiscation of criminal assets
- Enforcing TF measures and adopting appropriate measures for NPOs
- Enacting the necessary amendments related to TFS
- Developing, adopting, and implementing the necessary framework to counter PF
Areas for further improvement
- The FATF has made the initial determination that Trinidad and Tobago has substantially completed its action plan and warrants an on-site assessment to verify implementation
Yemen
Date first entered into agreement: February 2010
Steps taken towards improving AML/CFT regime
- Adequately criminalising money laundering and terrorist financing
- Establishing procedures to identify and freeze terrorist assets
- Improving its customer due diligence and STR requirements
- Establishing a fully operational and effectively functioning FIU
- Developing the monitoring and supervisory capacity of the FIU and financial sector supervisory authorities
Areas for further improvement
- While the FATF determined that Yemem has completed its agreed action plan, due to the security situation, the FATF has been unable to conduct an on-site visit.
Zimbabwe
Date first entered into agreement: October 2019
Steps taken towards improving AML/CFT regime
- Establishing a national coordination and cooperation structure on AML/CFT issues
- Amending the AML/CFT legal framework to apply a risk-based approach to supervision of FIs and DNFBPs
- Widening the scope of disseminating financial intelligence
- Establishing an asset forfeiture unit within the National Prosecuting Authority
Areas for further improvement
- Improving understanding of key ML/TF risks and implementing national AML/CFT policy based on the identified risks
- Implementing risk-based supervision for FIs and DNFBPs including through capacity building among the supervisory authority
- Applying proportionate and dissuasive sanctions to breaches
- Maintaining accurate and updated beneficial ownership information and ensuring timely access by authorities
