The Financial Action Task Force (FATF) issued the latest documents relating to the ‘High-Risk Jurisdictions subject to a Call for Action’ and ‘Jurisdictions under Increased Monitoring’.
Entities and individuals subject to the Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR) are obliged to assess the risks emanating from any jurisdiction they are dealing with, including whether they deal with jurisdictions considered as non-reputable or high-risk jurisdictions. Hence, it is crucial for subject persons to stay well-informed about the updates contained in such documents and implement such updates, primarily through updating the Jurisdiction Risk Assessment (JRA). Additionally, subject persons are required to carrying out enhanced due diligence measures when dealing with natural or legal persons established or linked with such jurisdiction.
In the recent update, the FATF introduced Bulgaria to the ‘Jurisdictions under Increased Monitoring’ which is also referred to as the ‘grey list’. In 2022, the Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism (MONEYVAL) assessed Bulgaria’s AML/CFT measures.
It resulted that Bulgaria achieved a moderate level of effectiveness regarding the assessment of ML/FT risks and domestic coordination, Terrorist Financing (TF) investigation, prosecution, preventive measures, and related targeted financial sanctions. Bulgaria also demonstrated a low level of effectiveness in areas related to the use of financial intelligence, ML investigations and prosecutions, confiscation of criminals’ proceeds of crime or property of equivalent value, proliferation financing related targeted financial sanctions and the prevention of misuse of legal persons and arrangements.
Since the MONEYVAL report, Bulgaria made progress in international cooperation and provided a high-level political commitment to address the deficiencies identified. The document highlighted that Bulgaria is to continue working on its FATF action plan to implement the recommendations outlined in the MONEYVAL report, with the aim to strengthen the effectiveness of its AML/CFT regime.
In October 2023, the FATF removed Albania, the Cayman Islands, Jordan, and Panama from the ‘Jurisdictions under Increased Monitoring’, hence these jurisdictions are no longer subject to increased monitoring.
To summarise, the countries in the ‘grey-list’ are currently: Barbados, Bulgaria, Burkina Faso, Cameroon, Democratic Republic of Congo, Croatia, Gibraltar, Haiti, Jamaica, Mali, Mozambique, Nigeria, Philippines, Senegal, South Africa, South Sudan, Syria, Tanzania, Türkiye, Uganda, United Arab Emirates, Vietnam, Yemen.
With regards the ‘High-Risk Jurisdictions subject to a Call for Action’, often referred to as ‘blacklist’, no changes were noted. Hence, countries in the ‘black-list’ include Iran, Democratic People’s Republic of Korea (DPRK) and Myanmar.
At Compliance 360 we can assist you. We can ease the responsibility of monitoring for document updates and ensuring your JRA is promptly updated with each change. We have developed a model which takes into consideration multiple reliable indices, covering more than 250 jurisdictions, and is continuously updated. Our assessment is based on the latest FIAU’s requirements and principles.
Contact us on firstname.lastname@example.org or 21360000 to receive further information on the JRA, or to explore other services offered by Compliance 360 Ltd.