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On 22nd August, FATF-style regional body GAFILAT published the 2nd follow-up report on Panama.  The original mutual evaluation report was adopted by GAFILAT in December 2017.  The new report says that, in general, Panama continues to make significant progress in addressing the Technical Compliance deficiencies identified in its MER and has been re-rated in FATF Recommendation 3 (from Partially Compliant to Largely Compliant), Recommendation 20 (from Partially Compliant to Compliant), Recommendation  24 (from Non-Compliant to Partially Compliant) and Recommendation 30 (from Partially Compliant to Compliant.) It also showed progress in Recommendation 25.  Panama will continue in the enhanced follow-up process and will continue to report to GAFILAT on the progress made to strengthen its implementation of AML/CFT measures.

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This blog is primarily for my own use, to keep informed and up to date. However, if you would like to say thank you (and perhaps help me get a new, better laptop when I am away…) you can “buy me a coffee” at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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