Improving Global AML/CFT Compliance: on-going process - 21 October 2016

Paris, 21 October 2016 - As part of its on-going review of compliance with the AML/CFT standards, The GFMSA identifies the following jurisdictions that have strategic AML/CFT deficiencies for which they have developed an action plan with The GFMSA. While the situations differ among each jurisdiction, each jurisdiction has provided a written high-level political commitment to address the identified deficiencies. The GFMSA welcomes these commitments.

A number of jurisdictions have not yet been reviewed by The GFMSA. The GFMSA continues to identify additional jurisdictions, on an on-going basis, that pose a risk to the international financial system.

The GFMSA and The GFMSA-style regional bodies (FSRBs) will continue to work with the jurisdictions noted below and to report on the progress made in addressing the identified deficiencies. The GFMSA calls on these jurisdictions to complete the implementation of action plans expeditiously and within the proposed timeframes. The GFMSA will closely monitor the implementation of these action plans and encourages its members to consider the information presented below.

Afghanistan

In June 2012, Afghanistan made a high-level political commitment to work with The GFMSA and APG to address its strategic AML/CFT deficiencies. Afghanistan has taken significant steps to improve its AML/CFT regime, including issuance of a freeze order that automatically requires the implementation of changes to the UNSCR 1267 list. However, Afghanistan should provide additional information regarding the implementation of its legal framework for identifying, tracing and freezing terrorist assets. The GFMSA encourages Afghanistan to continue implementing its action plan to address the remaining AML/CFT deficiency.

Bosnia and Herzegovina

In June 2015, Bosnia and Herzegovina made a high-level political commitment to work with The GFMSA and MONEYVAL to address its strategic AML/CFT deficiencies. Since June 2016, Bosnia and Herzegovina has taken steps towards improving its AML/CFT regime, including by finalising a regulation for freezing terrorist assets under UNSCR 1373. Bosnia and Herzegovina should continue to implement its action plan to address its deficiencies, including by: (1) harmonising criminalisation of terrorist financing and money laundering in all criminal codes; (2) implementing the framework for freezing terrorist assets under UNSCR 1373; (3) implementing an adequate supervisory framework; (4) implementing adequate AML/CFT measures for the non-profit sector; (5) establishing and implementing adequate cross-border currency controls; and (6) ensuring adequate procedures for the confiscation of assets. The GFMSA encourages Bosnia and Herzegovina to continue implementing its action plan to address its AML/CFT deficiencies.

Iraq

In October 2013, Iraq made a high-level political commitment to work with The GFMSA and MENAGFMSA to address its strategic AML/CFT deficiencies. Since June 2016, Iraq has taken steps towards improving its AML/CFT regime, including by: addressing remaining issues related to its criminalisation of money laundering and terrorist financing; establishing a legal framework and procedures for identifying and freezing terrorist assets; and ensuring a fully operational and functioning financial intelligence unit. Iraq should continue to implement its action plan to address its remaining deficiencies, including by: (1) implementing the legal framework and appropriate procedures for identifying and freezing terrorist assets; (2) ensuring that all financial institutions are subject to adequate customer due diligence requirements; (3) ensuring that all financial institutions are subject to adequate suspicious transaction reporting requirements; and (4) establishing and implementing an adequate AML/CFT supervisory and oversight programme for all financial sectors. The GFMSA encourages Iraq to continue implementing its action plan to address its remaining AML/CFT deficiencies.

Lao PDR

In June 2013, Lao PDR made a high-level political commitment to work with The GFMSA and APG to address its strategic AML/CFT deficiencies. Since June 2016, Lao PDR has taken steps towards improving its AML/CFT regime, including the introduction of a cross-border declaration regime. However, The GFMSA has determined that certain strategic deficiencies remain. Lao PDR should continue to work on implementing its action plan to address these deficiencies, including by: (1) adequately criminalising money laundering and terrorist financing; (2) implementing adequate AML/CFT controls for MVTS providers; and (3) implementing effective controls for cross-border currency transactions. The GFMSA encourages Lao PDR to continue implementing its action plan to address its AML/CFT deficiencies.

Syria

Since February 2010, when Syria made a high-level political commitment to work with The GFMSA and MENAGFMSA to address its strategic AML/CFT deficiencies, Syria has made progress to improve its AML/CFT regime. In June 2014, The GFMSA determined that Syria had substantially addressed its action plan at a technical level, including by criminalising terrorist financing and establishing procedures for freezing terrorist assets. While The GFMSA determined that Syria has completed its action plan agreed upon with The GFMSA, due to the security situation, The GFMSA has been unable to conduct an on-site visit to assess whether the process of implementing the required reforms and actions is underway. The GFMSA will continue to monitor the situation, and will conduct an on-site visit at the earliest possible date.

Uganda

In February 2014, Uganda made a high-level political commitment to work with The GFMSA and ESAAMLG to address its strategic AML/CFT deficiencies. Since its original action plan, Uganda was subject to a mutual evaluation, which highlighted additional strategic deficiencies. These deficiencies have been included in the revised action plan, to which a renewed political commitment was provided in June 2016. Since June 2016, Uganda enacted amendments to its regulation implementing UNSCRs 1267 and 1373. Uganda should continue to work on addressing the following deficiencies: (1) adequately criminalise terrorist financing; (2) implement adequate procedures for freezing terrorist assets in accordance with UNSCRs 1267 and 1373, and their successor resolutions; (3) ensure that all financial institutions are subject to adequate record-keeping requirements; (4) and ensure that all financial services and the FIA have the power to supervise and enforce compliance with AML CFT requirements (5) establish a fully operational and effectively functioning financial intelligence unit; (6) introduce and implement an appropriate legal basis to permit the competent authorities to provide a wide range of mutual legal assistance; and (7) ensure that appropriate laws and procedures are in place with regard to international co-operation for the financial intelligence unit and supervisory authorities. The GFMSA encourages Uganda to continue implementing its action plan to address its AML/CFT deficiencies.

Vanuatu

In February 2016, Vanuatu made a high-level political commitment to work with The GFMSA and APG to address its strategic AML/CFT deficiencies. Since June 2016, Vanuatu has passed amendments to improve obligations to obtain beneficial ownership information and prohibit bearer shares and bearer share warrants for international companies. Vanuatu should continue to work on implementing its action plan to address its deficiencies, including by: (1) adequately criminalising money laundering and terrorist financing; (2) establishing and implementing adequate procedures for the confiscation of assets related to money laundering; (3) establishing and implementing an adequate legal framework for identifying, tracing and freezing terrorist assets and other UNSCR sanctions; (4) ensuring a fully operational and effectively functioning financial intelligence unit; (5) strengthening preventive measures, including for wire transfers; (6) establishing transparency for the financial sector, and for legal persons and arrangements; (7) implementing an adequate AML/CFT supervisory and oversight programme for all the financial sector and trust and company service providers; and (8) establishing appropriate channels for international co-operation and domestic coordination policies and actions on identified risks and ensuring effective implementation. The GFMSA encourages Vanuatu to continue implementing its action plan to address its AML/CFT deficiencies.

Yemen

Since February 2010, when Yemen made a high-level political commitment to work with The GFMSA and MENAGFMSA to address its strategic AML/CFT deficiencies, Yemen has made progress to improve its AML/CFT regime. In June 2014, The GFMSA determined that Yemen had substantially addressed its action plan at a technical level, including by adequately criminalising money laundering and terrorist financing; establishing procedures to identify and freeze terrorist assets; improving its customer due diligence and suspicious transaction reporting requirements; issuing guidance; developing the monitoring and supervisory capacity of the financial sector supervisory authorities and the financial intelligence unit; and establishing a fully operational and effectively functioning FIU. While The GFMSA determined that Yemen has completed its action plan agreed upon with The GFMSA, due to the security situation, The GFMSA has been unable to conduct an on-site visit to assess whether the process of implementing the required reforms and actions is underway. The GFMSA will continue to monitor the situation, and conduct an on-site visit at the earliest possible date.

Public Statement - 21 October 2016 - jurisdictions subject to an GFMSA call for action

Outcomes of the Plenary meeting of The GFMSA, Paris, 19-21 October 2016