The list is comprised jurisdictions that are under increased monitoring and are actively working with the FATF to address strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing.
When FATF places a jurisdiction under increased monitoring, it means the country has committed to resolve swiftly the identified strategic deficiencies within agreed timeframes. This list is often externally referred to as the “grey list”.
COUNTRIES ON THE FATF GREY LIST
Algeria
Angola
Bolivia
Bulgaria
Cameroon
Côte d'Ivoire
Democratic Republic of the Congo
Haiti
Kenya
Lao PDR
Lebanon
Monaco
Namibia
Nepal
South Sudan
Syria
Venezuela
Vietnam
Virgin Islands (UK)
Yemen
NO LONGER SUBJECT TO FATF INCREASED MONITORING
The following jurisdictions have been removed from the Grey List, because FATF has witnessed significant improvement to their regimes to counter money laundering, terrorist financing, and proliferation financing.
Burkina Faso
Mozambique
Nigeria
South Africa
If your practice has clients that are actively engaged with jurisdictions listed on the Grey List, you should take additional care by carrying out regular, enhanced risk assessments and ensure that you carry out ongoing enhanced due diligence on all transactions. You should also seek to establish the source of any funds that come from any of the above jurisdictions, whether via invoices or cash injections into a client’s business.
If you have clients who are actively engaged with any of the jurisdictions that are no longer under FATF increased monitoring, you should still proceed with caution.
Any of the dealings detailed above must also be reflected in your Whole Practice Risk Assessment and updated immediately to reflect any change or unusual activity.
If you have any concerns, you should immediately contact the ICB AML Compliance Team by telephone on 0203 405 4000, or by email on aml@bookkeepers.org.uk
FATF BLACK LIST
As the title suggests, the following jurisdictions are those under severest scrutiny and are subject to a FATF call for action.
Democratic People’s Republic of Korea
Iran
Myanmar
ICB’s guidance to members is not to engage with jurisdiction on the FATF Black List without first talking to ICB or taking independent legal advice. Again, If you have any concerns, you should immediately contact the ICB AML Compliance Team by telephone on 0203 405 4000, or by email on aml@bookkeepers.org.uk
The ICB AML Compliance Team exists to provide ICB members with accurate information and guidance to enable them to identify risk and to take appropriate action to avoid being complicit with any form of illegal or questionable activity. Because ICB is in regular contact with other Professional Body Supervisors, government departments and Law Enforcement, ICB has up to date information and, where necessary, has the resources to contact others for advice and guidance to assist its members to reach satisfactory conclusion to any circumstances or concerns that arise. Please remember that such matters must not be discussed with any external person or organisation, and certainly not discussed on any social media platforms.
