The Financial Action Task Force (FATF) has added two new jurisdictions to its ‘grey list’ of countries under increased monitoring.
Bolivia and the British Virgin Islands (UK) have been added to the list of jurisdictions that have strategic AML/CFT deficiencies but have committed to work with the FATF to resolve them quickly. If your clients or matters have links to either jurisdiction, you must reassess the risk and document your rationale clearly.
Following successful completion of their FATF action plans, Croatia, Mali and Tanzania have been removed from the grey list. They have demonstrated positive progress and will now continue working with their regional bodies to maintain momentum.
The full grey list is now:
Algeria
Angola
Bolivia
Bulgaria
Burkins Faso
Cameroon
Cote d’Ivoire
Democratic Republic of the Congo
Haiti
Kenya
Lao PDR
Lebanon
Monaco
Mozambique
Namibia
Nepal
Nigeria
South Africa
Soth Sudan
Syria
Venezuela
Vietnam Virgin Islands (UK)
Yemen
What this means for your practice
In the event that you have clients in these jurisdictions, or you have clients who have suppliers or customers in these jurisdictions, you must carry out enhanced due diligence and be aware of uncreased transactional risk. It might be that your client is unaware of the risks associated with dealing with companies in these jurisdictions, in which case you should have a conversation with them to explain the FATF guidance and its implications. You should then work with them to ensure that any transactions are necessary, and you must urge them to introduce increased due diligence and monitoring. You should also carry out your own background investigations and checks.
Update your policies
If you have clients who are linked to, or deal with any of these jurisdictions, you must make sure your AML policies and procedures reflect this higher-level risk, and that the risks are incorporated into your Whole Practice Risk Assessment.
If you have any doubts, need more information, or need additional advice or support, please contact the ICB AML team on 0203 405 4000 or by email at aml@bookkeepers.org.uk
