Jurisdictions under Increased Monitoring - June 2021

Myanmar committed at a high level to work with the FATF and APG to strengthen the effectiveness of its AML/CFT regime and address any technical deficiencies. Myanmar should continue to work on implementing its action plan to address its strategic deficiencies, including by: (a) demonstrating a better understanding of ML risks in key areas; (2) demonstrating that onsite/offsite inspections are risk-based; (3) enhancing the use of financial intelligence in LEA investigations, and enhancing disseminations by the FIU; (four) ensuring ML is investigated/prosecuted based on risk; (5) demonstrating international collaboration in investigating transnational ML; (6) demonstrating an increase in the freezing/seizing and confiscation of criminal proceeds, instrumentalities, and/or property of equivalent value; (7) managing seized assets to preserve the value of seized goods until confiscation; and (8) demonstrating implementation of targeted financial sanctions related to PF, including training on sanctions evasion.

After making a high-level political commitment to work with the FATF and GAFILAT to improve the effectiveness of its AML/CFT regime in February 2020, Nicaragua has improved its AML/CFT regime, including by updating its national risk assessment on ML/TF. Among the steps Nicaragua should take to address its strategic deficiencies are: (1) disseminating the results of its ML/TF risk understanding to competent authorities and relevant private sector entities; (2) conducting effective, risk-based supervision; and (3) taking appropriate measures to prevent legal persons and arrangements from being misused. 

Pakistan has made significant progress across a comprehensive CFT action plan since the country's commitment to work with the FATF and APG on strengthening its AML/CFT regime and addressing its strategic counter-terror financing-related deficiencies, which was announced in June 2018. Since February 2021, Pakistan has been working on two of the three remaining CFT action plan items, and notes that Pakistan's targeted financial sanctions regime has been effectively redirected to target terrorist assets. The FATF acknowledges Pakistan's progress and efforts in addressing these CFT action plan items, and notes that Pakistan has made progress to complete two of the three remaining action items. Twenty-six of the 27 items in Pakistan's 2018 action plan have been completed. As soon as possible, the FATF urges Pakistan to address the one remaining CFT-related item by demonstrating that TF investigations and prosecutions target senior leaders and commanders of UN-designated terrorist groups.

Further deficiencies were identified in Pakistan's 2019 APG Mutual Evaluation Report (MER), Pakistan has addressed a number of the recommendations in the MER and committed further to address these strategic deficiencies pursuant to a new action plan that primarily focuses on combating money laundering. It is crucial that Pakistan address its AML/CFT deficiencies by: (1) enhancing international cooperation by amending the MLA law; (2) demonstrating that foreign assistance is being sought in the implementation of UNSCR 1373; other countries in order to implement UNSCR 1373 designations; (3) demonstrating that on-site and off-site supervision are being conducted in accordance with the specific risks associated with DNFBPs ((4) demonstrating a consistent application of proportionate and dissuasive sanctions to all legal persons and legal arrangements for non-compliance with beneficial ownership requirements; (5) increasing the number of ML investigations and prosecutions, including working with foreign counterparts to trace, freeze, and confiscate assets in accordance with Pakistan's risk profile; and (6) demonstrating that DNFBPs are monitored for compliance with proliferation financing requirements, as well as sanctions against those who do not comply.

Since June 2019, when Panama made a high-level political commitment to work with the FATF and GAFILAT to strengthen its AML/CFT regime, Panama has taken steps to improve the effectiveness of its AML/CFT regime, including taking steps to identify unlicensed money remitters and expanding the use of FIU products for ML investigations. Nevertheless, Panama should take urgent steps to complete the remaining measures in its action plan as all deadlines have expired. Therefore, Panama should continue to implement its action plan to address its strategic shortcomings, including by: (1) strengthening its understanding of the ML/TF risk of legal persons as part of the corporate sector and informing its national policies to mitigate the identified risks; (2) applying a risk-based approach to supervision of the DNFBP sector, ensuring effective, proportionate, and dissuasive sanctions against AML/CFT violations; (3) ensuring adequate verification of beneficial ownership information by duty-bearers and timely access by competent authorities; assessing the existing risks of misuse of legal persons and arrangements to define and implement specific measures to prevent the use of nominee shareholders and directors; and (4) demonstrating its ability to investigate and prosecute financial crimes involving foreign tax and continuing to provide constructive and timely international cooperation for such offences, and continuing to focus on ML investigations related to high-risk areas.

Panama has made progress across its action plan; however, all deadlines have expired and there is still a great deal to be done. Panama is therefore strongly urged to complete its full action plan and address the above-mentioned strategic deficiencies as soon as possible.

Philippines made a high-level commitment in June 2021 to work with the FATF and APG to strengthen its AML/CFT regime. Several of the Philippines' MER-recommended actions have been implemented since the completion of its MER in 2019, including addressing technical deficiencies about targeted financial sanctions. As part of its action plan, the Philippines will demonstrate: (1) that effective risk-based supervision is occurring for DNFBPs; (2) that supervisors are using AML/CFT controls to mitigate risk associated with casino junkets; (3) enhancing registration requirements for MVTS and applying sanctions to unregistered and illegal remittance operators; (4) improving access to BO information and ensuring that BO information is accurate and up-to-date; (5) increasing financial intelligence use and increasing ML investigation and prosecution in line with risk; (6) demonstrating an increase in the detection, investigation, and prosecution of TF cases; (7) showing that appropriate measures are taken to protect the NPO sector (including unregistered NPOs) without disrupting legitimate NPO operations; and (8) strengthening the targeted financial sanctions framework for both TF and PF.

(Statement from February 2021)

In February 2021, Senegal committed to strengthen the effectiveness of its AML/CFT regime with the FATF and GIABA. Senegal has made progress since the completion of its MER in 2018, including by adopting a National Strategy for AML/CFT and an Operational Plan for implementing the Strategy. To implement its action plan, Senegal will: (1) ensure that all relevant authorities are aware of ML/TF risks (in particular those related to the DNFBP sector through training and outreach; (2) seek MLA and other forms of international cooperation that are appropriate in light of its risk profile; (3) regulate Financial Institutions and DNFBPs adequately and effectively; (4) update and maintain comprehensive beneficial ownership information, and strengthen the system of sanctions for transgressions of transparency obligations; (5) enhancing the FIU's capabilities by increasing its personnel; (6) demonstrating that efforts aimed at strengthening detection mechanisms and expanding the capability to carry out ML/predicate offences investigations and prosecutions consistent with Senegal's risk profile are sustained; (7) establishing comprehensive and uniform policies and procedures for identifying, tracing, confiscating, and seizing proceeds and instruments of crime in line with their risk profile; (8) enhancing capacity and support for law enforcement and prosecutors addressing terrorist financing; and (9) implementing a targeted financial sanctions regime related to terrorist financing and proliferation financing, as well as risk-based monitoring and supervision of NPOs.

South Sudan made a high-level political commitment in June 2021 to strengthen its AML/CFT regime. As part of its implementation plan, South Sudan will: (1) apply for membership in the ESAAMLG and pledge to undergo a mutual evaluation with the ESAAMLG or another assessment body; (2) conduct a thorough review of the AML/CFT Act (2012), including technical assistance to conform to the FATF Standards; (3) designating a body to coordinate ML/TF risk assessments at national level; and (4) ratification of the Vienna Convention of 1988, the Palermo Convention of 2000, and the Terrorist Financing Convention of 1999 ; (5) the competent authorities must be capable of implementing a risk-based approach to AML/CFT supervision of financial institutions; (6) develop a comprehensive legal framework to ensure the accuracy of beneficial ownership information; (7) establishing a fully functional and independent FIU; and (8) developing a legal and institutional framework for the implementation of targeted financial sanctions in line with U.N. Security Council Resolutions on terrorism and proliferation financing; and (9) implementing targeted risk-based supervision of NPOs at risk of TF abuse.

Syria has made progress in its AML/CFT reforms since it made a high-level political commitment to work with the FATF and MENAFATF to address its strategic deficiencies in AML/CFT in February 2010. In June 2014, the FATF confirmed Syria had substantially implemented its action plan, including criminalizing terrorist financing and freezing terrorist assets. Syria has been found to have completed its agreed action plan by the FATF, but the FATF has not been able to conduct an on-site visit to confirm whether the necessary reforms and actions are being implemented. An on-site visit will be conducted by the FATF as soon as possible.

Uganda pledged to work with the FATF and ESAAMLG to strengthen the effectiveness of its AML/CFT regime in February 2020. Since then, Uganda has taken a few steps toward improving its AML/CFT regime, including adopting the National AML/CFT Strategy in September 2020 and completing the ML/TF risk assessment. Legal entities and contractual arrangements. Uganda should continue to work to implement its action plan to address its strategic deficiencies, including by: (1) seeking international cooperation in line with the country’s risk profile; (2) developing and implementing risk-based supervision of FIs and DNFBPs; (3) ensuring that competent authorities have timely access to accurate basic and beneficial ownership information for legal entities; (4) demonstrating LEAs and judicial authorities apply the ML offence consistent with the identified risks; (5) establishing and implementing policies and procedures for identifying, tracing, seizing and confiscating proceeds and instrumentalities of crime; (6) demonstrating that LEAs conduct TF investigations and pursue prosecutions commensurate with Uganda’s TF risk profile; (7) addressing the technical deficiencies in the legal framework to implement PF-related targeted financial sanctions and implementing a risk-based approach for supervision of its NPO sector to prevent TF abuse. The FATF is monitoring Uganda’s oversight of the NPO sector. Uganda is urged to apply the risk-based approach to supervision of NPOs in line with the FATF Standards.

In the months following Yemen's high-level political commitment to work with the FATF and MENAFATF to address its strategic AML/CFT deficiencies, Yemen has made progress toward improving its AML/CFT regime. In June 2014, the FATF determined that Yemen had substantially addressed its action plan at a technical level, including by: (1) adequately criminalising money laundering and terrorist financing; (2) establishing procedures to identify and freeze terrorist assets; (3) improving its customer due diligence and suspicious transaction reporting requirements; (4) issuing guidance; (5) developing the monitoring and supervisory capacity of the financial sector supervisory authorities and the financial intelligence unit; and (6) establishing a fully operational and effectively functioning financial intelligence unit. Due to the security situation, the FATF has been unable to conduct an on-site visit to verify whether the process of implementing the required reforms and actions has begun and is continuing. FATF will continue to monitor the situation and conduct an on-site visit as soon as possible.

With the commitment Zimbabwe made in October 2019 to work with the FATF and ESAAMLG to strengthen its AML/CFT regime and address any technical deficiencies, Zimbabwe has taken steps to improve its AML/CFT regime, including by developing risk-based supervision manuals for financial institutions and higher-risk DNFBPs to reflect the newly identified risks. The country should continue to implement its action plan, including: (1) establishing risk-based supervision for FIs and DNFBPs, including by building supervisory authority capacity; (2) ensuring effective risk mitigation measures by FIs and DNFBPs, including by applying proportionate and dissuasive sanctions when breaches occur; (3) ensuring that competent authorities have access to up-to-date beneficial ownership information; and (4) addressing remaining gaps in the targeted financial sanctions framework and demonstrating implementation. 

Jurisdiction No Longer Subject to Increased Monitoring by the FATF

FATF welcomes Ghana's significant progress in improving its AML/CFT system. As part of Ghana's action plan regarding the strategic deficiencies that the FATF identified in October 2018, it has strengthened the effectiveness of its AML/CFT regime and addressed associated technical deficiencies. The FATF is therefore no longer monitoring Ghana. GIABA and Ghana will continue to work together to improve Ghana's AML/CFT regime.