Source document: https://docs-lawep.s3.us-east-2.amazonaws.com/1697633205110.pdf (Antigua and Barbuda)
ANTIGUA AND BARBUDA NATIONAL OVERSIGHT COMMITTEE ON FINAIICIAL ACTION NOCFA ONDCP; FSRC; ECCB To: And to: Financial Institutionsl Dated: 25 March2022 ADVISORY on Jurisdictions with AML/CFT Deficiencies This Advisory is issued by NOCFA to its Members pursuant to the mandate to publish advisories under its Terms of Reference.2 Supervisors and Regulators should disseminate the information herein to the financial institutions3which they supervise to enable them to take the information into consideration in their business activities as required by law.a It should also be circulated to Govemment Deparfinents and statutory bodies.
The Advisory relates to foreign jurisdictions with AML/CFTs deficiencies and includes (i) High-risk jurisdictions subject to a call for action and (ii) Jurisdictions under increased monitoring due to strategic deficiencies The Advisory sets out actions to be implemented and rvhere needed, countermeasures to be taken by regulated financial institutions and Government deparbnents.

Responding to this Advisory 1.

Supervisors and Regulators must distribute this Advisory to the entities they supervise/regulate.
2.

Financial lnstitutions to whom this Advisory is provided are required to acknowledge receipt to the authority that provides it.

3.

Financial Institutions should take this Advisory into account when considering transactions or business involving the jurisdictions referred to herein (and where called upon, apply enhanced, proportionate due diligence).
PART I - High Risk Jurisdictions Subject to a Call for Action - March2022 Since February 2020, in light of the COVID- 19 pandemic, the FATF has paused the review process for countries in ttrLe list of High-Risk Jurisdictions subject to a Call for Action, given that they are I See First Schedule ofthe Money Laundering (Prevention) Act 1996 and section 2 ofthe Prevention ofTenorism Act 2005.

2 "ln furtherance of its objective, the NOCFA shall:- ... 3. act as a coordination task force.
taliing measures including publication ofadvisories, notices and countermeasures to ensure that relevant Authorities understand their respective supervisory role and responsibilities;" 3 See financial institutions as defined in the First Schedule ofthe Money Laundering (Prevention) Act 1996 and section 2 ofthe Prevention of Tenorism Act 2005.

4Reg.
4Reg.

*6(1a) [A financial institution] must pay special attention to business relationships and transactions with persons from or in countries which [the financial institution] knows or has reason to believe insufhciently apply intemational standards against money laundering or the financing of tenorism.

financial institutionl must pay special attention to business relationships and transactions from or in that country.
(2) If the Supervisory Authority notifies [a financial institution] that a country has weaknesses in its AML/CFT systems, then [the (lb) Where transactions have no apparent economic or visible lawful purpose, [the frnancial institution] should examine as far as possible (lc) [A financial institution] should adhere to any countermeasures that the Supervisory Authority or the regulator advises should be the background and purpose ofsuch transactions, and written findings should be kept as a financial transaction document.
implemented."

5 AML/CFT: anti-money laundering/counter terrorist frnancing already subject to the FATF's call for countermeasures.

Therefore, please refer to the statement on these jurisdictions adopted in February 2020.

While the statement may not necessarily reflect the most recent status of Iran and the Democratic People's Republic of Korea's AML/CFT regimes, the FATF's call for action on these high-risk jurisdictions remains in effect.
FATF Public Statement of October 2021 (frrst adopted 21 February 2020'S High-risk jurisdictions have significant strategic deficiencies in their regimes to counter money laundering, terrorist financing, and financing of proliferation.
For all countries identified as high-risk, the FATF calls on all members and urges all jurisdictions to apply enhanced due diligence, and in the most serious cases, countries are called upon to apply counter-measures to protect the international financial system from the ongoing money laundering, terrorist financing, and proliferation financing (ML/TF/PF)6 risks emanating from the country.

1.
1.

DEMOCRATTC PEOPLE'S REPUBLIC OF KOREA (DPRK) The FATF remains concerned by the DPRK's failure to address the significant deficiencies in its anti-money laundering and combating the financing of terrorism (AML/CFT) regime and the serious threats they pose to the integrity of the international financial system.

The FATF urges the DPRK to immediately and meaningfully address its AML/CFT deficiencies.
Further, the FATF has serious concerns with the threat posed by the DPRK's illicit activities related to the proliferation of weapons of mass destruction (WMDs) and its financing.

The FATF reaffirms its 25 February 2OLt call on its members and urges alljurisdictions to advise their financial institutions to give special attention to business relationships and transactions with the DPRK, including DPRK companies, financial institutions, and those acting on their behalf.
In addition to enhanced scrutiny, the FATF further calls on its members and urges alljurisdictions to apply effective counter-measures, and targeted financial sanctions in accordance with applicable United Nations Security Council Resolutions, to protect their financial sectors from money laundering, financing of terrorism and WMD proliferation financing (ML/TF/PF) risks emanating from the DPRK.
Jurisdictions should take necessary measures to close existing branches, subsidiaries and representative offices of DPRK banks within their territories and terminate correspondent relationships with DPRK banks, where required by relevant UNSC resolutions.

2.

IRAN ln June 2076, lran committed to address its strategic deficiencies.

lran's action plan expired in January 2018.

In February 2020, the FATF noted lran has not completed the action plan.
[1] In October 2019, the FATF called upon its members and urged all jurisdictions to: require increased supervisory examination for branches and subsidiaries of financial institutions based in lran; introduce enhanced relevant reporting mechanisms or systematic reporting of financial transactions; and require increased external audit requirements for financial groups with respect to any of their branches and subsidiaries located in lran.
Now, given lran's failure to enact the Palermo and Terrorist Financing Conventions in line with the FATF Standards, the FATF fully lifts the suspension of counter-measures and calls on its members 6 Section 7A ofthe Prevention ofTenorism Act (PTA) prohibits transactions with specified entities.

Section 20B ofthe PTA prohibits making funds available to specified entities.
"specified entity" means a person or entity in respect ofwhich an order under section 3(2) has been made by the Attomey General, or is deemed by reason of the operation of section 4(2) to have been made by the Minister of Foreign Affairs, and is in force; and urges all jurisdictions to apply effective counter-measures, in line with Recommendation te.l2J lran will remain on the FATF statement on [High Risk Jurisdictions Subject to a Call for Action] until the full Action Plan has been completed.
lf lran ratifies the Palermo and Terrorist Financing Conventions, in line with the FATF standards, the FATF will decide on next steps, including whether to suspend countermeasures.

Until lran implements the measures required to address the deficiencies identified with respect to countering terrorism-financing in the Action Plan, the FATF will remain concerned with the terrorist financing risk emanating from lran and the threat this poses to the international financial system.
PART 2 - Jurisdictions under Increased Monitoring due to Strategic Deficiencies in their AML/CFT rregimes FATF Statement of March 2022 on Jupisdictions under increased monitoring Jurisdictions under increased monitpring are actively working with the FATF to address strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing.
When the FATF places a jprisdiction under increased monitoring, it means the country has committed to resolve swiftly the identified strategic deficiencies within agreed timeframes and is subject to increased monitoring.

Since the start of the COVID-19 panflemic, the FATF has provided some flexibility to jurisdictions not facing immediate deadlines to report progress on a voluntary basis.
The following countries had their progress reviewed by the FATF since October 2021: Albania, Barbados, Burkina Faso, Cambodia, Cayman lslands, Jamaicq, Malta, Morocco, Myanmar, Nicaragua, Pakistan, Panama, Philippines, Senegal, South Sudan, [1,lganda, and Zimbabwe.

For these countries, updated statements are provided on the FAI|F website.
Jordan, Mali, Haiti, and Turkey were given the opportunity and chose to defer reporting; thus, the statements issued in June and Octobe r 2O2L for these jurisdictions can be found on the FATF website, but they may not necessarily reflect the most recent status of the jurisdiction's AML/CFT regime.

Following review, the FATF now also identifies the United Arab Emirbtes.
(click on country name below to go tO FATF online country report for details) Jurisdictions with strategic deficiencies Jurisdiction no longer subject to increased monitoring Zimbabwe Albania Barbados Burkina Faso Cambodia Cavman lslands Haiti lamaica Jordan Mali Malta Morocco MVanmar Nicaragua Pakistan Panama Philippines Senegal South Sudan Svria Turkey Usanda United Arab Emirates Yemen PART 3 -,Iurisdictions under the CFATF ICRGT Process [See last NOCFA Advisory issued 10 December 2021] NOCFA Reminder: Complementing the requirements regarding jurisdictions listed in PART 1 above, financial institutions should pay special attention to individuals and entities connected to these jurisdictions, bearing in mind - (a) lt is an offence for a financial institution to engage in any transactions with persons or entities declared specified entities or proliferation entities by the Minister of Foreign Affairs or suspected of being engaged in the proliferation of WMD (a proliferation entitf) - see section 7A(1) of the Prevention of Terrorism Act [amended by section 7 of the Prevention of Terrorism (Amendment) Act No.
11 of 20201.

(b) lt is an offence for anyone to make available for the benefit of a specified entity or proliferation entity any funds, assets, economic resources, or financial or other related services unless authorized by a relevant United Nations Security Council Resolution - see sections 208(a) and (2) of the Prevention of Terrorism Act [amended by section 11 of the Prevention of Terrorism (Amendment) Act No.

tl, of 2O2Ol.
tl, of 2O2Ol.

(c) Where a financial institution is unable to satisfy itself that a transaction is not related to the financing of terrorism or the financing of the proliferation of WMD then it should consider not proceeding with it.

Financial institutions should review the Appendix to the MLFT Guidelines titled "lndicators of Possible Proliferation Financing"s, issued by the ONDCP Supervisory Authority on 12 Decembdr2OtT.
(d) "specified entit/' is a person or entity declared to be a specified entity by order of the Minister of Foreign Affairs under section al2l of the Prevention of Terrorism Act.
7 Intemtional Co-operation Review Group 8 "proliferation entity" is a person or entity engaged in the proliferation of or the financing of the proliferation of'Veapons of mass destruction" 9 www.ondcp.gov.ag (e) "proliferation entity" is a person or entity engaged in the proliferation of or the financing of the proliferation of weapons of mass destruction or declared to be a proliferation entity by the Minister of Foreign Affairs under section a(3) of the Prevention of Terrorism Act.
on behalf of the National Oversight Committee on Financial Action