AML/CFT FOLLOW-UP REPORTS: MACAO, MONGOLIA AND SRI LANKA

On 1st October, FATF-style regional body APG published follow-up reports on the 3 territories following their previous mutual evaluation reports.  As is usual, the reports address only changes (if any) in technical compliance ratings – but do not address effectiveness ratings.

Note that Macao, has become the first jurisdiction in the world to achieve LC/C ratings on all 40 Recommendations.

  • Sri Lanka – 4th follow-up report, the MER having been published in September 2015. Sri Lanka has made progress in addressing more of its technical compliance deficiencies identified in its MER and has been upgraded on 4 FATF Recommendations. Recommendations 7, 25 and 38 are now rated LC and 37 is now rated C.  Important progress has been made with supervision, but moderate shortcomings are noted.  As such Recommendation 26 remains at PC while Recommendation 28 is upgraded to PC. With respect to the Recommendations amended after the adoption of Sri Lanka’s MER, the review team assessed Sri Lanka’s compliance with the amendments made to Recommendations 2, 5, 8, 18 and 21 after the adoption of Sri Lanka’s MER.  Sri Lanka has retained the ratings previously assigned in either its MER or earlier follow-up reports for all the recommendations amended.  Sri Lanka will remain on enhanced follow-up, and will continue to report back to the APG on progress to strengthen its implementation of AML/CFT measures.sl
  • Mongolia – this is the 2nd follow-up report following the MER of July 2017. The report says that Mongolia has made significant progress in addressing the technical compliance deficiencies identified in its MER and has been upgraded on 16 FATF Recommendations. Recommendation 28 has been upgraded to PC and Recommendations 2, 6, 7, 17, 19, 22, 23, 24, 25, 26, 32, 33 and 34 have been upgraded to LC.  Recommendations 21 and 29 have been re-rated to C.  However, insufficient progress has been made on Recommendations 1, 8, 14 and 35 to justify a re-rating at this time.  With respect to the other Recommendations which have been amended after the MER was adopted, Mongolia has retained its ratings for Recommendations 5 and 18.  Mongolia exited enhanced follow-up (expedited) and was placed on enhanced follow-up. Mongolia will continue to report back to the APG on progress to strengthen its implementation of AML/CFT measures.mongolia
  • Macao – this is the first follow-up report, the MER being released in December 2017. It says that Macao has made good progress in addressing the technical compliance deficiencies identified in its MER, including through drafting revised legislation and guidelines, and has been upgraded on 3 FATF Recommendations.  Macao was upgraded to LC on Recommendations 22, 23 and 32.  With respect to the FATF Recommendations amended after the adoption of the MER – Recommendations 2, 5, 7, 18 and 21 – Macao has retained the ratings given in the MER.  Macao has no Recommendations remaining at NC/PC. It will remain on regular follow-up, and will continue to report back to the APG on progress to strengthen its implementation of AML/CFT measures.macao

http://www.apgml.org/news/details.aspx?pcPage=1&n=1151

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 https://www.buymeacoffee.com/KoIvM842y

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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