FATF: HIGH-RISK JURISDICTIONS SUBJECT TO A CALL FOR ACTION – FEBRUARY 2023
FATF statement
FATF regularly publishes a list of countries that have significant strategic deficiencies in their national AML/CFT/CPF regimes. For the countries that are considered to be of high risk, all jurisdictions should apply enhanced due diligence or, in the most serious cases, apply countermeasures in order to protect the international financial system from the effects of the money laundering, terrorist financing or financing of proliferation risks emerging from those countries.
In its most recent statement of 24 February 2023 (High-Risk Jurisdictions subject to a Call for Action – 24 February 2023 (fatf-gafi.org)), FATF calls on its members and other jurisdictions to apply countermeasures against the Democratic People’s Republic of Korea (DPRK) and Iran. FATF referred to its statement of February 21, 2020 (Documents – Financial Action Task Force (FATF) (fatf-gafi.org)) and reiterated that although the review process for these countries is paused due to the COVID-19 pandemic, its call for countermeasures remains in effect.
Furthermore, FATF has called upon members and other jurisdictions to apply enhanced due diligence measures against Myanmar. FATF decided that further action was necessary due to the lack of progress in the completion of action items in Myanmar’s action plan. Nonetheless, these measures should be proportionate to the risks arising from the jurisdiction and they should not hinder flows of funds for the purpose of humanitarian assistance, legitimate NPO activity and remittances.
Responsibility of reporting entities
Pursuant to article 11 of the AML/CFT State Ordinance, designated financial and non-financial service providers are required to conduct enhanced customer due diligence if a business relationship or a transaction by its nature entails a higher risk of money laundering, terrorist financing or financing of proliferation. The identification of high-risk countries by the FATF increases the level of AML/CFT/CPF risk in a business relationship or a transaction. Service providers should take the necessary measures to mitigate the increased risk.
Considering the above, it is important to remain alert for red flags when conducting transactions involving the countries referred to in this FATF statement. If there is reason to assume that a transaction (i.e. financial transaction/service) is related to AML/CFT/CPF, this should be reported promptly to FIU-Aruba in an unusual transaction report under the subjective indicator 130201 or 130202.
Additionally, FIU-Aruba reiterates the importance of conducting a ‘sanctions-check’ to determine whether transaction(s) must be reported objectively under indicator 130102 (see in particular: “Aanwijzing geconsolideerde lijst VNSC” and “Aanwijzing EU Sancties Bevriezingsmaatregelen”) and to determine whether national freezing measures are applicable.
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