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FATF warning lists

Three times a year, the FATF releases lists of jurisdictions with strategic deficiencies in their anti-money laundering and combating the financing of terrorism (AML/CFT) regimes. There are two types of FATF warning lists: High-Risk Jurisdictions subject to a Call for Action (also known as the "black list”) and Jurisdictions under Increased Monitoring (also known as the "grey list").

High-Risk Jurisdictions subject to a Call for Action (the “black list”)

This list includes countries that have significant deficiencies in their AML/CFT regimes. These deficiencies may pose a major risk to the international financial system. Moreover, the countries on the black list have not committed themselves to an action plan to address the deficiencies identified.

The FATF expects its members to ensure that financial institutions conduct enhanced customer due diligence with regard to business relationships and transactions related to countries on this list. In the most serious cases, the FATF also calls on its members to take countermeasures against countries on this list in order to protect the international financial system.

The black list consists of the following countries: Iran, North Korea and Myanmar.

Iran

In February 2020, the FATF renewed its call for countermeasures on Iran, saying it had not completed its action plan to address the serious deficiencies in its AML/CFT regime. At its October 2021 plenary session, the FATF reaffirmed that the February 2020 call for countermeasures remained unchanged. It remains particularly concerned about Iran's high risk of terrorist financing and the threat this entails to 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 relations in connection with Iran. Based on the FATF recommendations, 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;

  • 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, among other factors, geographic risk factors when establishing whether transactions qualify as unusual. This also includes the involvement in transactions of parties from countries without effective AML/CFT systems, such as Iran.

North Korea

The FATF remains concerned about North Korea's failure to address the significant deficiencies in its AML/CFT regime, and the serious threat this poses to the integrity of the international financial system. The FATF also has serious concerns with the threat posed by North Korea's nuclear proliferation and its financing. DNB and the Ministry of Finance emphasise 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.

Myanmar

In February 2020, Myanmar committed to address its strategic deficiencies in its AML/CFT regime.
Given the continued lack of progress and the fact that the majority of its action items have still not been addressed after the expiry of the action plan deadline, the FATF called on its members to apply enhanced due diligence measures proportionate to the risk arising from Myanmar. When applying enhanced due diligence measures, countries should ensure that flows of funds for humanitarian assistance, legitimate NPO activity and remittances are not disrupted.

The FATF urges Myanmar to work to fully address its AML/CFT deficiencies. Myanmar will remain on the list of countries subject to a call for action until its full action plan is completed.

Jurisdictions under Increased Monitoring (the “grey list”)

Jurisdictions under Increased Monitoring are countries that have serious deficiencies in their AML/CFT regimes but have expressed their commitment to address these. The FATF encourages its members to consider the specific circumstances of these countries in their AML/CFT risk assessments and measures. For each country on the list, the FATF explains the deficiencies identified and the actions that the country has committed to for addressing these deficiencies. After each plenary session, the FATF updates its statements according to the country's progress on these actions.

This list includes the following jurisdictions:

  • Bulgaria
  • Burkina Faso
  • Cameroon
  • Croatia
  • Democratic Republic of the Congo
  • Haiti
  • Jamaica
  • Kenya
  • Mali
  • Mozambique
  • Namibia
  • Nigeria
  • Philippines
  • Senegal
  • South Africa
  • South Sudan
  • Syria
  • Tanzania
  • Türkiye
  • Vietnam
  • Yemen

Financial institutions are expected take the specific circumstances regarding these countries into account when taking AML/CFT measures.