FinCEN Urges Institutions to Review AML Program Around Jurisdictions FATF Identified Have AML/CTF Deficiencies
In the second issuance, jurisdictions identified as having strategic AML/CFT deficiencies for which an action plan has been developed with FATF are outlined. FATF notes that each region listed does demonstrate a high-level political commitment to address deficiencies. FinCEN directs institutions to ensure due diligence programs, especially those addressing correspondent accounts with foreign institutions, including appropriate risk-based policies and controls to detect and report suspicious activity. Jurisdictions added since the June list include The Bahamas, Botswana and Ghana.
As always, when jurisdictions are added or removed, BSA professionals should read FATF’s reasoning and make their own decisions when assessing risk. That means you should not blindly remove jurisdictions from what you consider areas of concern without considering your individual risk profile and customer base. Keeping up with updates from FATF and FinCEN are material to the success of your program.
As BSA professionals, you protect our nation every day. We thank you for that today and every day!