FATF: Jurisdictions under Increased Monitoring in 2024

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On February 23, 2024, the Financial Action Task Force (FATF) announced a list of jurisdictions under increased monitoring, commonly referred to as the “grey list.” These jurisdictions are actively collaborating with the FATF to address deficiencies in their anti-money laundering (AML), counter-terrorist financing (CFT), and counter-proliferation financing (CPF) regimes. Being on the grey list means these countries have committed to swiftly resolving identified strategic deficiencies within agreed timeframes and are subject to heightened scrutiny. The FATF and its regional bodies are working closely with these jurisdictions to monitor their progress and encourage timely completion of action plans. However, the FATF does not advocate for enhanced due diligence measures to be applied to these jurisdictions, emphasising the importance of a risk-based approach.

The FATF continuously identifies additional jurisdictions with strategic deficiencies and provides flexibility for reporting progress voluntarily. Since October 2023, the FATF reviewed the progress of several countries, including Barbados, Bulgaria, Burkina Faso, Croatia, the Democratic Republic of Congo, Gibraltar, Jamaica, Mali, Mozambique, Nigeria, the Philippines, Senegal, South Africa, South Sudan, Tanzania, Turkey, the UAE, and Uganda. Kenya and Namibia have also been added to the list following recent reviews. Some countries such as Cameroon, Haiti, Syria, Vietnam, and Yemen opted to defer reporting, and their previous statements are included but may not reflect the most current status of their AML/CFT regimes.

BULGARIA

Since October 2023, Bulgaria has made a high-level political commitment to collaborate with the FATF and MONEYVAL to enhance the effectiveness of its anti-money laundering and counter-terrorist financing regime. Progress has been made in addressing technical compliance deficiencies related to Recommendations 6, 10, and 24. To further improve its AML/CFT framework, Bulgaria needs to implement its national AML/CFT Strategy by adopting a comprehensive action plan, address remaining technical compliance gaps, initiate risk-based supervision for certain entities, ensure accuracy of beneficial ownership information, and complete the implementation of automated processes.

BURKINA FASO

Since February 2021, Burkina Faso has committed to strengthening its anti-money laundering and counter-terrorist financing regime in collaboration with the FATF and GIABA. Progress includes increased investigations and prosecutions related to terrorist financing in accordance with the country’s risk assessment. However, Burkina Faso must continue implementing its action plan to address strategic deficiencies, such as enhancing supervisory capacities, maintaining accurate ownership information, diversifying suspicious transactions reporting, establishing procedures for cross-border currency transportation declarations, and implementing effective terrorist financing and proliferation financing regimes, as noted by the FATF. Despite progress, all deadlines have passed, prompting the FATF to urge Burkina Faso to expedite implementation of these measures.

CAMEROON

In June 2023, Cameroon committed to enhancing its anti-money laundering and counter-terrorist financing regime in collaboration with the FATF and GABAC. Progress since October 2021 includes bolstering the resources of the FIU and building the capacity of investigation authorities. Cameroon aims to align national AML/CFT strategies with NRA findings, prioritise international cooperation requests, enhance risk-based supervision for financial institutions, ensure access to beneficial ownership information, improve information exchange between relevant entities, strengthen ML investigations and prosecutions, establish procedures for asset seizure and confiscation, and effectively implement terrorist financing and proliferation financing regimes while adopting a risk-based approach to NPOs.

DEMOCRATIC REPUBLIC OF CONGO

Since October 2022, when the DRC made a high-level political commitment to work with the FATF and GABAC to strengthen the effectiveness of its AML/CFT regime, the DRC has taken steps towards improving its AML/CFT regime, including by finalising their three-year AML/CFT National Strategy. The DRC should continue to work to implement its FATF action plan to address its strategic deficiencies, including by: (1) disseminating the NRA on ML and TF to all key stakeholders; (2) developing and implementing a risk-based supervision plan; (3) building the capacity of the FIU to conduct operational and strategic analysis; (4) strengthening the capabilities of authorities involved in the investigation and prosecution of ML and TF; and (5) demonstrating effective implementation of TF and PF-related TFS. 

CROATIA

Since June 2023, Croatia has been dedicated to enhancing its anti-money laundering and counter-terrorist financing regime in collaboration with the FATF and MONEYVAL. Progress includes completing its national risk assessment. To address strategic deficiencies, Croatia aims to increase FIU resources and analytical capabilities, improve law enforcement’s ability to detect and prosecute various types of money laundering, enhance the application of provisional measures for securing proceeds, systematically detect and investigate terrorist financing, establish a framework for implementing UN terrorism financing measures, and identify vulnerable non-profit organisations for targeted outreach and training.

HAITI

Since June 2021, Haiti has committed to strengthening its anti-money laundering and counter-terrorist financing regime in collaboration with the FATF and CFATF. Progress includes improving information sharing with foreign counterparts and addressing technical deficiencies in its AML/CFT framework despite challenging social, economic, and security conditions. Haiti aims to complete its risk assessment process, implement risk-based supervision for financial institutions and high-risk DNFBPs, maintain accessible ownership information, enhance the use of financial intelligence, improve identification and prosecution of money laundering cases, increase proceeds recovery, address technical deficiencies in targeted financial sanctions, and conduct risk-based monitoring of vulnerable NPOs. Despite progress, all deadlines have passed, prompting the FATF to encourage Haiti to continue implementing its action plan to address strategic deficiencies.

JAMAICA

In February 2020, Jamaica pledged to enhance its anti-money laundering and counter-terrorist financing regime in collaboration with the FATF and CFATF. By February 2024, the FATF determined that Jamaica had largely completed its action plan, necessitating an on-site assessment to verify sustained implementation and political commitment. Jamaica’s reforms include enhancing its understanding of money laundering and terrorist financing risks, expanding AML/CFT coverage to all relevant sectors with adequate supervision, preventing misuse of legal entities, improving ML investigations and prosecutions, implementing targeted financial sanctions for terrorist financing, and adopting a risk-based approach to supervising the non-profit sector to mitigate terrorism financing risks.

KENYA 

In February 2024, Kenya committed to strengthening its anti-money laundering and counter-terrorist financing regime in partnership with the FATF and ESAAMLG. Progress since September 2022 includes legislative amendments aligning with FATF recommendations and establishing a case management system for international cooperation requests. Kenya’s action plan entails completing a terrorist financing risk assessment, enhancing risk-based supervision for financial institutions and non-financial businesses, improving preventive measures compliance, regulating trusts, enhancing financial intelligence usage, increasing money laundering and terrorist financing investigations, ensuring timely targeted financial sanctions implementation, and revising non-profit organisation regulation to align with risk mitigation and legitimate activities.

MALI 

Since October 2021, Mali has been committed to enhancing its anti-money laundering and counter-terrorist financing regime in collaboration with the FATF and GIABA. Progress includes assessing ML/TF risks associated with legal entities, conducting parallel financial investigations for terrorism cases, and strengthening the legal framework for targeted financial sanctions. Mali aims to address strategic deficiencies by ensuring timely access to accurate beneficial ownership information, identifying and investigating terrorist financing activities, implementing targeted financial sanctions related to terrorism and proliferation financing, and adopting a risk-based approach to monitor the nonprofit sector. Despite progress, all deadlines have passed, prompting the FATF to encourage Mali to expedite the implementation of its action plan.

MOZAMBIQUE

In October 2022, Mozambique committed to bolstering its AML/CFT regime with the FATF and ESAAMLG. Progress includes improved inter-agency cooperation, LEA training on mutual legal assistance, and a comprehensive TF risk assessment. Mozambique aims to provide resources for risk-based supervision, establish accurate beneficial ownership records, enhance FIU capabilities and financial intelligence sharing, strengthen LEAs’ ML/TF investigation skills, begin a national CFT strategy, raise TF and PF-related TFS awareness, and conduct a TF risk assessment for NPOs. Despite strides, implementation of the action plan is vital to address remaining deficiencies, emphasising Mozambique’s ongoing commitment to enhancing its AML/CFT framework.

NAMIBIA

In February 2024, Namibia pledged to bolster its AML/CFT regime in collaboration with the FATF and ESAAMLG. Progress since September 2022 includes improving ML/TF/PF risk understanding among stakeholders and enhancing international cooperation. Namibia’s action plan entails strengthening risk-based supervision by enhancing capacities, conducting inspections, and applying dissuasive sanctions. Preventive measures include enhancing due diligence and targeted financial sanctions compliance. Efforts focus on increasing beneficial ownership information filing, enhancing FIU capabilities, improving FIU-LEA cooperation, enhancing operational capabilities for investigations and prosecutions, and approving an amended National Counter Terrorism Strategy. Implementation of the action plan is vital for addressing deficiencies, underlining Namibia’s commitment to enhancing its AML/CFT framework.

NIGERIA

Since February 2023, Nigeria has committed to enhancing its AML/CFT regime with the FATF and GIABA. Progress includes updating national strategies, establishing asset confiscation data mechanisms, and conducting targeted outreach to vulnerable NPOs. Nigeria’s action plan includes disseminating residual ML/TF risk assessments, enhancing international cooperation, improving risk-based supervision and preventive measures for high-risk sectors, ensuring timely access to beneficial ownership information, increasing financial intelligence dissemination and use, boosting money laundering investigations and prosecutions, detecting currency declaration violations, intensifying terrorism financing investigations, and implementing risk-based NPO monitoring to prevent abuse. Continued implementation is crucial to addressing deficiencies and reinforcing Nigeria’s AML/CFT framework.

PHILIPPINES

Since June 2021, the Philippines committed to enhancing its AML/CFT regime with the FATF and APG, making progress in identifying and investigating terrorism financing cases. The action plan involves effective risk-based supervision of DNFBPs, mitigating risks associated with casino junkets, enhancing LEA access to beneficial ownership information, increasing money laundering and terrorism financing investigations and prosecutions. The FATF urges swift implementation of the action plan to address strategic deficiencies, with all deadlines expired in January 2023. Continued efforts are essential to reinforce the Philippines’ AML/CFT framework.

SENEGAL

Since February 2021, Senegal has committed to enhancing its AML/CFT regime with the FATF and GIABA, improving detection of violations, establishing accurate beneficial ownership information mechanisms, and strengthening targeted financial sanctions. Senegal’s action plan includes enhancing compliance of high-risk entities with reporting obligations and implementing risk-based monitoring of NPOs vulnerable to terrorism financing abuse. While Senegal has made progress, all deadlines expired by September 2022, prompting the FATF to urge swift action to address strategic deficiencies. Continued implementation is crucial to reinforce Senegal’s AML/CFT framework.

SOUTH AFRICA

Since February 2023, South Africa committed to enhancing its AML/CFT regime with the FATF and ESAAMLG, addressing technical deficiencies in its targeted financial sanction regime and increasing financial intelligence utilisation. The action plan includes boosting outbound mutual legal assistance requests, improving DNFBP supervision, ensuring timely access to beneficial ownership information, increasing money laundering and terrorism financing investigations and prosecutions, enhancing asset identification and confiscation, updating terrorism financing risk assessments, and effectively implementing targeted financial sanctions. Despite progress, continued efforts are crucial, as all deadlines have passed, emphasising the need to address strategic deficiencies promptly to reinforce South Africa’s AML/CFT framework.

SOUTH SUDAN

In June 2021, South Sudan pledged to enhance its AML/CFT regime with the FATF and ESAAMLG, completing its ML/TF National Risk Assessment. The action plan entails reviewing and updating AML/CFT legislation, implementing international conventions, enhancing competent authorities’ capacity for risk-based supervision, establishing a legal framework for beneficial ownership information, operationalizing an independent FIU, implementing targeted financial sanctions, and initiating risk-based supervision of NPOs vulnerable to terrorism financing abuse. Despite limited progress and expired deadlines, the FATF urges South Sudan to promptly implement the action plan, emphasising political and institutional commitment to strengthen the AML/CFT regime, particularly in coordinating national efforts.

SYRIA

Since February 2010, Syria committed to addressing its AML/CFT deficiencies with the FATF and MENAFATF. By June 2014, Syria substantially addressed its action plan, criminalising terrorist financing and establishing procedures for freezing terrorist assets. However, due to security concerns, the FATF hasn’t conducted an on-site visit to confirm sustained implementation of reforms. Monitoring continues, with plans for an on-site visit when feasible.

TANZANIA

Since October 2022, Tanzania committed to enhancing its AML/CFT regime with the FATF and ESAAMLG, focusing on LEA capacity building and addressing technical deficiencies in targeted financial sanctions. Action plan includes improving risk-based supervision, enhancing investigative capabilities, seizing and confiscating proceeds of crime, conducting comprehensive terrorism financing risk assessment, implementing national CFT strategy, raising private sector and competent authority awareness on TF-related targeted financial sanctions, and conducting terrorism financing risk assessment for NPOs. Continued efforts are essential to address strategic deficiencies and reinforce Tanzania’s AML/CFT framework.

TÜRKIYE

In October 2021, Türkiye pledged to enhance its AML/CFT regime with the FATF, with the FATF determining in February 2024 that Türkiye substantially completed its action plan. Reforms include improved risk-based supervision, dissuasive sanctions for breaches, enhanced FIU resources and financial intelligence use, complex money laundering investigations, improved asset recovery, prioritised terrorism financing investigations, enhanced targeted financial sanctions implementation, and broad NPO outreach with risk-based supervision to safeguard legitimate activities. The FATF seeks an on-site assessment to verify sustained implementation and political commitment, highlighting Türkiye’s significant strides in bolstering its AML/CFT framework.

VIETNAM

In June 2023, Vietnam committed to strengthening its AML/CFT regime with the FATF and APG, making progress since its MER adoption in November 2021. The action plan includes enhancing risk understanding and coordination, international cooperation, implementing risk-based supervision, regulating virtual assets, addressing technical compliance deficiencies, conducting private sector outreach, establishing a beneficial ownership regime, ensuring FIU independence, prioritising financial investigations, and monitoring compliance with proliferation financing targeted financial sanctions. Vietnam aims to bolster its AML/CFT framework through comprehensive reforms and cooperation among authorities to prevent proliferation financing evasion.

YEMEN

Since February 2010, Yemen has worked with the FATF and MENAFATF to address AML/CFT deficiencies, substantially meeting its action plan by June 2014, including criminalising money laundering and terrorist financing, establishing asset freezing procedures, enhancing due diligence and reporting requirements, issuing guidance, and strengthening supervisory authorities and the FIU. Despite completion, security concerns have hindered an on-site visit to verify sustained reforms. The FATF remains vigilant, aiming for an on-site assessment soon to ensure ongoing implementation and address Yemen’s AML/CFT situation comprehensively.

Jurisdictions No Longer Subject to Increased Monitoring by the FATF

Barbados, Gibraltar, Uganda, and the United Arab Emirates (UAE) have made significant strides in enhancing their AML/CFT regimes, leading to the removal of increased monitoring by the FATF. Barbados addressed supervision effectiveness, beneficial ownership transparency, FIU capacity, and ML prosecutions. Gibraltar improved sanctions for AML/CFT breaches and pursued confiscation judgments. Uganda adopted an AML/CFT strategy, enhanced supervision, addressed beneficial ownership issues, and improved investigations. The UAE increased MLA requests, strengthened DNFBP supervision, mitigated legal person abuse, boosted FIU capacity, enhanced ML investigations, and ensured effective TFS implementation. Each jurisdiction is urged to sustain these advancements through continued collaboration with relevant bodies.

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