On 22 January, FATF-style regional body GAFILAT published the Fourth Regular Monitoring and Requalification Report on Technical Compliance of the Republic of Cuba.  It analyses the country’s progress towards addressing technical compliance deficiencies identified in its Mutual Evaluation Report (MER) of 2015 (after which Cuba was placed in the regular follow-up process).  It is said that Cuba has addressed its technical compliance deficiencies identified in the MER in relation to –

FATF Recommendation 31, originally rated PC, now Compliant;

FATF Recommendation 28, originally rated PC, now compliant; and

FATF Recommendation 35, originally rated PC and which has not been re-rated. 

The report also reviews other FATF Recommendation ratings since the MER, with Recommendation 15 (new technologies) downgraded from C to PC.  Cuba will continue in the regular follow-up process and will continue to report to GAFILAT on the progress made to strengthen its implementation of AML/CFT measures.

If you would like to make a (polite) gesture and make a (very) modest contribution to my ongoing with my relocation, removal and computer costs, I have a page 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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