On 21 February, FATF reported on the week-long Plenary held in Paris.  The Plenary discussed the general matters of understanding and leveraging the use of digital identity, and mitigating the money laundering and terrorist financing risks of virtual assets.

It considered mutual evaluation reports on the UAE and South Korea – due to be published in April, and a follow-up report on the US with 1 FATF Recommendation on technical compliance to be re-rated.

Re jurisdictions under increased monitoring to address strategic AML/CFTCPF deficiencies –

  • Trinidad & Tobago was removed from such monitoring, due to the significant progress it has made in addressing the strategic AML/CFT deficiencies identified earlier by the FATF and included in its action plan;
  • but Albania, Barbados, Jamaica, Mauritius, Myanmar, Nicaragua and Uganda were added – although FATF welcomed their high-level political commitment to their action plans.; and
  • the Plenary also considered Pakistan’s actions in addressing its deficiencies. It noted that, to date, Pakistan has largely addressed 14 of 27 action items, with varying levels of progress made on the rest of the action plan; and FATF strongly urges Pakistan to swiftly complete its full action plan by June 2020.

For these countries subject to increased monitoring (and the other 10 also subject to increased monitoring), see –


Re “high-risk” jurisdictions – Iran will remain on the FATF statement on High Risk Jurisdictions Subject to a Call for Action until the full Action Plan has been completed.  Given Iran’s failure to enact the Palermo and Terrorist Financing Conventions in line with the FATF Standards, FATF fully lifted the suspension of counter-measures and called on its members and urges all jurisdictions to apply effective counter-measures against Iran.  For more information on the “high-risk” jurisdictions, i.e. Iran and North Korea, see – http://www.fatf-gafi.org/publications/high-risk-and-other-monitored-jurisdictions/documents/increased-monitoring-february-2020.html

Other business –

  • the Plenary discussed progress on one of its priorities under the Chinese FATF Presidency: to tackle the financial flows linked to the illegal wildlife trade;
  • FATF will develop guidance on risk-based AML/CFT supervision. This guidance will set out how supervisors in member countries can assess ML/TF risks to their sectors and how they can develop supervision programmes based on these risks; and
  • the Plenary discussed progress in the strategic review of its mutual evaluation and follow-up processes.



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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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