On 15th December, FATF issued a report following up its evaluation of the AML/CFT/CPF systems in Austria.  It analyses Austria’s progress in addressing the technical compliance deficiencies identified in the mutual evaluation report. The report also looks at whether Austria has implemented new measures to meet the requirements of FATF Recommendations that have changed since their 2016 mutual evaluation.  It also details re-rating of the results Austria received against several FATF Recommendations in 2016on its technical compliance.


The Institute for Science and International Security also produced this interesting paper in September 2017.  It states that apart from Saudi Arabia, which the Institute views as currently the largest proliferation risk in the Middle East, 3 key neighbours of Iran also warrant intensive study as to their nuclear capabilities and plans, safeguards and obstacles to proliferation, and future proliferation risks.  None of these are countries which most people would immediately highlight as obvious proliferation risks – but given the general levels of instability, if not outright conflict, across the larger Middle East region, any or all states in the region might be considered a risk.


The Peterson Institute for International Economics (a US-based non-partisan think tank) on 14th December published an article lauding 2 recent reports from C4DS (“The Forex Effect” – see earlier blog post) and the Institute for Science and International Security for high-quality open-source reporting on North Korean trade and investment.

The latter report is said to be apart of a larger project called the Peddling Peril Index (PPI), which ranks 200 countries, territories, and entities “according to their capabilities and demonstrated success in implementing strategic export controls.”   The index comes replete with a color-coded ranking of countries on the quality of their export control regimes and the likelihood of corruption. The report identifies no fewer than 49 countries involved in sanctions violations and of 4 types –

  • military-related (13):

Angola, Cuba, DR Congo, Egypt, Eritrea, Iran, Mozambique, Myanmar, Namibia, Sri Lanka, Syria, Uganda, and Tanzania.

  • non-military related that involved facilitating front companies, financial transactions, and other business activities (18):

Angola, Brazil, Bulgaria, China, Egypt, Ethiopia, Germany, India, Iran, Malaysia, Namibia, Poland, Romania, Russia, Singapore, Sri Lanka, Sudan, Syria, and UAE.

  • import of sanctioned goods (19):

Barbados, China, Costa Rica, Egypt, El Salvador, France, Germany, India, Indonesia, Iran, Ireland, Malaysia, Mexico, Pakistan, Philippines, Sri Lanka, Syria, and Vietnam.

  • reflagging of ships and shipping-related violations (20): Brazil, Cambodia, China, Egypt, Fiji, Greece, Japan, Kiribati, Malaysia, Marshall Islands, Mongolia, Palau, Panama, Peru, Russia, Sierra Leone, Singapore, Tanzania, Thailand, and Togo.

The main point of the brief is to show the accuracy of the PPI in predicting such violations. But the list actually contains a lot of surprises: Sri Lanka, Germany, France, Brazil, Mexico, Peru, Barbados; and the article calls for further enforcement work, such as by FATF.  As one might expect, the results of the study suggest that North Korea has often targeted countries with weak or non-existent export and proliferation financing controls and those that suffer on average from more corruption than other countries.

The Institute for Science and International Security study is at –