Financial Crimes Enforcement Network Issues an Advisory Notice

On July 20, 2015, the Financial Crimes Enforcement Network (FinCEN) issued an advisory announcing that the Financial Action Task Force (FATF) had updated its list of jurisdictions with strategic Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) deficiencies. Financial institutions should consider these changes when reviewing their enhanced due diligence obligations and risk-based policies, procedures and practices with respect to the jurisdictions noted below. Jurisdictions that are subject to the FATF's call for countermeasures or are subject to enhanced due diligence based on their AML/CFT deficiencies include: Iran, Democratic People's Republic of Korea, Algeria and Myanmar. Jurisdictions identified by the FATF as having AML/CFT deficiencies include: Afghanistan, Angola, Bosnia and Herzegovina, Ecuador, Guyana, Iraq, Lao PDR, Panama, Papua New Guinea, Sudan, Syria, Uganda and Yemen.

A copy of the advisory notice is available at:

http://www.fincen.gov/statutes_regs/guidance/pdf/FIN-2015-A002.pdf

It is imperative that financial institutions carefully review current AML practices and procedures to ensure that all facets of their operations are fully compliant. If you have questions about this Alert, please contact Daniel Viola at 212.573.8038 or dviola@sglawyers.com.

Cheryl Spratt