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FATF Warning lists - December 2020 update

News item supervision

Published: 30 December 2020

The Financial Action Task Force (FATF) released two documents, indicating jurisdictions with strategic deficiencies in their anti-money laundering and combating the financing of terrorism (AML/CFT) regimes.

  1. High-Risk Jurisdictions subject to a Call for Action – 23 October 20201
  2. Jurisdictions under Increased Monitoring – 23 October 20202

The “jurisdictions under increased monitoring” have demonstrated their commitment to addressing the identified deficiencies. Other countries have made less progress, such as the high-risk jurisdictions referred to in the FATF's “Call for Action” (North Korea, Iran).

Impact of COVID-19 on the monitoring process
Due to the COVID-19 situation, the FATF has decided on a general pause in the review process for jurisdictions with deficiencies. This is why the December documents refer to the earlier documents published in February 2020. These February documents and the FATF’s call for tighter measures with respect to these countries therefore continue to apply, even if they do not necessarily provide an up-to-date picture of the situation in these countries3. The February documents can be found here:

  1. High-Risk Jurisdictions subject to a Call for Action – 21 February 2020
  2. Jurisdictions under Increased Monitoring – 21 February 2020


In June 2016, Iran drafted an action plan in consultation with the FATF to address the serious deficiencies in its AML/CFT regime. The FATF then partially suspended the call for tighter measures against Iran and monitored the country's progress. In its plenary meeting of February 2020, the FATF concluded that Iran's progress in addressing the serious deficiencies in its AML/CFT regime was still insufficient. The FATF has therefore lifted its suspension of countermeasures against Iran. It is particularly concerned about Iran's high risk of terrorist financing and the threatening impact thereof on 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 relationships in connection with Iran. 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, and 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 geographic risk factors when establishing whether transactions qualify as unusual based on the subjective indicator. This also includes the involvement in transactions of parties from countries without effective AML/CFT systems, such as Iran.

Last but not least, DNB and the Ministry of Finance remind institutions of the recent amendment of Section 9 of the Anti-Money Laundering and Anti-Terrorist Financing Act (Wet ter voorkoming van witwassen en financieren van terrorisme – Wwft. This amendment means that institutions will be explicitly obliged to take tighter measures with respect to transactions, business relations and correspondent banking relations in connection with high-risk countries such as Iran.

North Korea

The FATF continues to be concerned about North Korea's serious deficiencies in addressing money laundering and terrorist financing, and the serious threat this poses to the integrity of the international financial system. The FATF is also highly concerned about the threat from North Korea's nuclear proliferation and proliferation funding. 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.

Jurisdictions under Increased Monitoring

The document “Jurisdictions under Increased Monitoring” lists the countries that have serious deficiencies in their AML/CFT systems but have expressed their commitment to address these. This list includes the following jurisdictions:4

  • Albania,
  • Barbados,
  • Botswana,
  • Cambodia,
  • Ghana,
  • Jamaica,
  • Mauritius,
  • Myanmar,
  • Nicaragua,
  • Pakistan,
  • Panama,
  • Syria,
  • Uganda,
  • Yemen and
  • Zimbabwe.

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

If necessary, the FATF will review its warning lists at its next plenary meeting (in February 2021). Due to the COVID-19 situation, the process may be delayed.

1 This document used to be referred to as the “Public Statement".
2 This document used to be referred to as "Improving Global AML/CFT Compliance: On-going Process".
3 The statements for Mongolia and Iceland, both on the list of jurisdictions under increased monitoring, have been updated since these jurisdictions requested the FATF not to extend their deadlines and continue on their current schedule.
4 The Bahamas has been removed from the list as per 18 December 2020. See: http://www.fatf-gafi.org/publications/high-risk-and-other-monitored-jurisdictions/documents/bahamas-delisting-2020.html.