Compliance Blog

Written by Ricardo Piñeres, Regulatory Compliance Counsel

FinCen Releases AML/CFT Deficiencies Advisory.  On August 5, the Financial Crimes Enforcement Network (FinCen) released FinCen Advisory FIN-2014-A006.  The release of this advisory comes as a response to the Financial Action Task Force (FATF) having updated its lists of jurisdictions with strategic Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) deficiencies.  Back in late-June, FATF updated its lists of jurisdictions that appear in two different documents:

• FATF Public Statement, which consists of  jurisdictions that are subject to FATF’s call for countermeasures or are subject to Enhanced Due Diligence due to their AML/CFT deficiencies; and
• Improving Global AML/CFT Compliance: On-going Process, which consists of jurisdictions identified by FATF to have AML/CFT deficiencies.

Based on the recent changes to FATF Public Statement, FinCen is advising that institutions apply counter-measures to protect the international financial system from the on-going and substantial money laundering and terrorist financing (ML/FT) risks emanating from Iran and North Korea.  Furthermore, FinCen is advising institutions to apply enhanced due diligence for following countries:

• Algeria;
• Ecuador;
• Indonesia; and
• Myanmar.

FATF recognized that Ethiopia, Pakistan, Syria, Turkey, and Yemen “have made progress in substantially or largely addressing their FATF action plan.”  Therefore, those countries were taken off the FATF Public Statement and have been placed on Improving Global AML/CFT Compliance: On-going Process.  Kenya, Kyrgyzstan, Mongolia, Nepal, and Tanzania were all deemed to have made “significant progress in addressing all or nearly all of their strategic AML/CFT deficiencies.”  Therefore, they were removed from Improving Global AML/CFT Compliance: On-going Process.  The list of countries now on Improving Global AML/CFT Compliance: On-going Process is as follows:

• Afghanistan;
• Albania;
• Angola;
• Argentina;
• Cambodia;
• Cuba;
• Ethiopia;
• Iraq;
• Kuwait;
• Lao PDR;
• Namibia;
• Nicaragua;
• Pakistan;
• Panama;
• Papua New Guinea;
• Sudan;
• Syria;
• Tajikistan;
• Turkey;
• Uganda;
• Yemen; and
• Zimbabwe.

See FinCen’s Advisory for further information on the changes to the lists and guidance regarding U.S. financial institutions’ responsibilities and restrictions with regards to the countries on the lists.

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Free Kick.  The dawn of a new season is upon us.  Yet, the transfer window will remain open for another 20 days.  While many of the Europe’s top clubs have tried to conduct the majority of their business on the front end of the transfer window, there will likely be a few more moves that will strengthen some teams and weaken some others.  Therefore, I refuse to make any predictions regarding the upcoming season until the window closes and we have some stability amongst the rosters of Europe’s elite squads.

All of that being said, I am still excited for what the season ahead brings for an Arsenal fan such as myself.  With the 3-0 victory over Manchester City in yesterday’s Community Shield, an offseason full of promise and activity has come to a close.  The additions of Alexis Sanchez, Callum Chambers, Mathieu Debuchy, and David Ospina have addressed needs and added some much-needed depth to the squad.  Hopefully, the team can remain relatively healthy this season because when the new additions are added to the likes of Theo Walcott, Aaron Ramsey, Santi Cazorla, Mesut Ozil, and Olivier Giroud, Arsenal should have one of the most exciting attacking squads in the EPL.  Go Gunners!!!