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FinCEN Updates List of Jurisdictions with AML/CFT Deficiencies

On November 12, the Financial Crimes Enforcement Network (FinCEN) issued an advisory announcing that the Financial Action Task Force (FATF) has updated its list of jurisdictions that have strategic deficiencies in their anti-money laundering (AML) and counter-terrorist financing (CFT) regimes. 

Specifically, FATF has noted that: (1) Iran and the Democratic People’s Republic of Korea are subject to the FATF’s call for countermeasures; (2) Algeria, Ecuador, Indonesia and Myanmar are subject to the FATF’s call for enhanced due diligence; (3) Argentina, Cuba, Ethiopia, Tajikistan and Turkey have been removed from the FATF listing and monitoring process; and (4) Guyana has been added to the list of jurisdictions identified by the FATF to have AML/CFT deficiencies, which now includes 18 countries. 

These changes may affect US financial institutions’ obligations and risk-based approaches with respect to the relevant jurisdictions. National Futures Association (NFA) has issued a notice reminding futures commission merchants and introducing brokers to review the FinCEN advisory to ensure that their AML programs have the most current information on FATF-identified jurisdictions with AML/CFT deficiencies, and revise their AML programs accordingly. 

The FinCEN Advisory is available here

The NFA Notice to Members is available here.

©2019 Katten Muchin Rosenman LLP


About this Author

Kevin M. Foley, Finance Lawyer, Katten Llaw Firm

Kevin M. Foley has extensive experience in commodities law and advises a wide range of clients, both in the United States and abroad, on compliance with the Commodity Exchange Act and the rules of the Commodity Futures Trading Commission (CFTC) affecting traditional exchange-traded products, as well as the over-the-counter markets involving swaps and other derivative instruments. His clients include futures commission merchants, derivatives clearing organizations, designated contract markets, foreign boards of trade and an industry trade association.



Timothy Kertland concentrates his practice on transactional, corporate and regulatory aspects of financial services matters. Timothy is able to provide legal services to a wide variety of clients including proprietary trading firms, hedge funds, broker-dealers, registered investment advisers, and commodity trading advisers.

While in law school, Timothy served as an editor of the Virginia Tax Review. As a first-year law student, he represented the University of Virginia School of Law at the National Transactional LawMeets Competition.