High-risk and non-cooperative jurisdictions
Improving Global AML/CFT Compliance: on-going process 22 June 2012
Rome, 22 June 2012 - As part of its on-going review of compliance with the AML/CFT standards, theFATF has to date identified the following jurisdictions which have strategic AML/CFT deficiencies forwhich they have developed an action plan with the FATF. While the situations differ among eachjurisdiction, each jurisdiction has provided a written high-level political commitment to address theidentified deficiencies. The FATF welcomes these commitments.
A large number of jurisdictions have not yet been reviewed by the FATF. The FATF continues to
identify additional jurisdictions, on an on-going basis, that pose a risk to the international financial
system.
The FATF and the FSRBs will continue to work with the jurisdictions noted below and to report on
the progress made in addressing the identified deficiencies. The FATF calls on these jurisdictions tocomplete the implementation of action plans expeditiously and within the proposed timeframes. The
FATF will closely monitor the implementation of these action plans and encourages its members toconsider the information presented below.
Afghanistan
Albania
Algeria
AngolaAntigua and Barbuda
Argentina
Bangladesh
Brunei Darussalam
Turkmenistan

Cambodia
KuwaitKyrgyzstan
Mongolia
MoroccoNamibia
Nepal

NicaraguaPhilippines
Sudan
Tajikistan
Trinidad and Tobago
Venezuela
Zimbabwe

Afghanistan
In June 2012, Afghanistan made a high-level political commitment to work with the FATF and APG toaddress its strategic AML/CFT deficiencies. Afghanistan will work on implementing its action plan toaddress these deficiencies, including by: (1) adequately criminalising money laundering andterrorist financing; (2) establishing and implementing an adequate legal framework for identifying,tracing and freezing terrorist assets: (3) implementing an adequate AML/CFT supervisory andoversight programme for all financial sectors; (4) establishing and implementing adequate
procedures for the confiscation of assets related to money laundering; (5) establishing a fully
operational and effectively functioning Financial Intelligence Unit; and (6) establishing andimplementing effective controls for cross-border cash transactions. The FATF encourages
Afghanistan to address its remaining deficiencies and continue the process of implementing its
action plan.

1

Improving Global AML/CFT Compliance: on-going process - 22 June 2012

Albania
In June 2012, Albania made a high-level political commitment to work with the FATF and
MONEYVAL to address its strategic AML/CFT deficiencies. Albania has taken steps towards
improving its AML/CFT regime. However, the FATF has determined that strategic AML/CFT
deficiencies remain. Albania will work on implementing its action plan to address these
deficiencies, including by: (1) implementing adequate customer due diligence provisions;(2) establishing and implementing an adequate legal framework for identifying, tracing andfreezing terrorist assets; and (3) enhancing the framework for international co-operation
related to terrorist financing. The FATF encourages Albania to address its remaining
deficiencies and continue the process of implementing its action plan.

Algeria
In October 2011, Algeria made a high-level political commitment to work with the FATF and
MENAFATF to address its strategic AML/CFT deficiencies. The FATF has concerns thatstrategic AML/CFT deficiencies remain and, therefore, further engagement with Algeria isneeded to clarify whether these deficiencies have been addressed. Algeria should continue
to work on implementing its action plan, including by: (1) adequately criminalising terrorist
financing; (2) establishing and implementing an adequate legal framework for identifying,tracing and freezing terrorist assets; (3) improving and broadening customer due diligencemeasures; and (4) ensuring a fully operational and effectively functioning Financial
Intelligence Unit (FIU). The FATF encourages Algeria to address its deficiencies and continue
the process of implementing its action plan.

AngolaIn June 2010, Angola made a high-level political commitment to work with the FATF to
address its strategic AML/CFT deficiencies. Since February 2012, Angola has taken steps
towards improving its AML/CFT regime, including by issuing customer due diligence
regulations. However, the FATF has determined that certain strategic AML/CFT deficiencies
remain. Angola should continue to work on implementing its action plan to address these
deficiencies, including by: (1) adequately criminalising money laundering and terrorist
financing; (2) ensuring a fully operational and effectively functioning Financial Intelligence
Unit; and (3) establishing and implementing an adequate legal framework to identify andfreeze terrorist assets without delay. The FATF encourages Angola to address its remaining
deficiencies and continue the process of implementing its action plan.

Antigua and Barbuda
In February 2010, Antigua and Barbuda made a high-level political commitment to workwith the FATF and CFATF to address its strategic AML/CFT deficiencies. The FATF has
determined that certain strategic AML/CFT deficiencies remain. Antigua and Barbuda
2

Improving Global AML/CFT Compliance: on-going process - 22 June 2012

should continue to work on implementing its action plan to address these deficiencies,
including by continuing to improve the overall supervisory framework and to work with theOrganisation of Eastern Caribbean States to this end. The FATF encourages Antigua andBarbuda to address its remaining deficiencies and continue the process of implementing its
action plan.

Argentina
In June 2011, Argentina made a high-level political commitment to work with the FATF to
address its strategic AML/CFT deficiencies. Since February 2012, Argentina has taken
substantial steps towards improving its AML/CFT regime, including by issuing a
Presidential Decree creating a framework for freezing terrorist-related assets and issuingfurther FIU resolutions to reporting parties. However, the FATF has determined that certain
strategic AML/CFT deficiencies remain. Argentina should continue to work on implementing
its action plan to address these deficiencies, including by: (1) addressing the remaining
deficiencies with regard to the criminalisation of money laundering; (2) further improving
procedures for the confiscation of funds related to money laundering and freezing terrorist
assets; (3) enhancing financial transparency; (4) ensuring a fully operational and effectivelyfunctioning Financial Intelligence Unit and improving suspicious transaction reporting
requirements; (5) further enhancing the AML/CFT supervisory programme for all financial
sectors; (6) further improving and broadening customer due diligence measures; and (7)establishing appropriate channels for international co-operation and ensuring effective
implementation. The FATF encourages Argentina to address its remaining deficiencies andcontinue the process of implementing its action plan.

Bangladesh
In October 2010, Bangladesh made a high-level political commitment to work with the FATF
and APG to address its strategic AML/CFT deficiencies. Since February 2012, Bangladesh hastaken steps towards improving its AML/CFT regime, including by enacting a Mutual Legal
Assistance Act. However, the FATF has determined that certain strategic AML/CFT
deficiencies remain. Bangladesh should continue to work on implementing its action plan toaddress these deficiencies, including by: (1) adequately criminalising terrorist financing; (2)establishing and implementing adequate procedures to identify and freeze terrorist assets;(3) ensuring a fully operational and effectively functioning Financial Intelligence Unit; (4)improving international co-operation; and (5) issuing guidance to capital markets
intermediaries to ensure their AML/CFT obligations are complied with. The FATF
encourages Bangladesh to address its remaining deficiencies and continue the process of
implementing its action plan.

Brunei Darussalam
In June 2011, Brunei Darussalam made a high-level political commitment to work with the FATF and
APG to address its strategic AML/CFT deficiencies. Since February 2012, Brunei Darussalam has
3Improving Global AML/CFT Compliance: on-going process - 22 June 2012

taken steps towards improving its AML/CFT regime, including by issuing the Criminal Asset
Recovery Order, 2012 and the Anti-Terrorism Order (Amendment) Order, 2012. However, the FATF
has determined that certain strategic AML/CFT deficiencies remain. Brunei Darussalam should
continue to work on implementing its action plan to address these deficiencies, including by: (1)establishing and implementing adequate procedures to identify and freeze terrorist assets; (2)ensuring a fully operational and effectively functioning Financial Intelligence Unit; and (3) enacting
and implementing appropriate mutual legal assistance legislation. The FATF encourages Brunei
Darussalam to address its remaining deficiencies and continue the process of implementing its
action plan.

Cambodia
In June 2011, Cambodia made a high-level political commitment to work with the FATF and APG toaddress its strategic AML/CFT deficiencies. The FATF has determined that certain strategic
AML/CFT deficiencies remain. Cambodia should continue to work on implementing its action plan toaddress these deficiencies, including by: (1) adequately criminalising money laundering andterrorist financing; (2) establishing and implementing adequate procedures to identify and freeze
terrorist assets; (3) establishing and implementing adequate procedures for the confiscation of funds
related to money laundering; (4) ensuring a fully operational and effectively functioning Financial
Intelligence Unit; and (5) establishing and implementing effective controls for cross-border cashtransactions. The FATF encourages Cambodia to address its remaining deficiencies and continue theprocess of implementing its action plan.

KuwaitIn June 2012, Kuwait made a high-level political commitment to work with the FATF and MENAFATF
to address its strategic AML/CFT deficiencies. Kuwait will work on implementing its action plan toaddress these deficiencies, including by: (1) adequately criminalising terrorist financing; (2)implementing the 1999 International Convention for the Suppression of Financing of Terrorism; (3)establishing and implementing adequate procedures to identify and freeze terrorist assets; (4)ensuring that appropriate laws and procedures are in place to provide mutual legal assistance; (5)establishing effective customer due diligence measures; (6) ensuring a fully operational andeffectively functioning Financial Intelligence Unit (FIU), in particular addressing the operational
autonomy of the FIU; and (7) ensuring that financial institutions are aware of and comply with their
obligations to file suspicious transaction reports in relation to money laundering and terrorist
financing. The FATF encourages Kuwait to address its remaining deficiencies and continue theprocess of implementing its action plan.

Kyrgyzstan
In October 2011, Kyrgyzstan made a high-level political commitment to work with the FATF and EAG
to address its strategic AML/CFT deficiencies. Since February 2012, Kyrgyzstan has taken steps
towards improving its AML/CFT regime, including by establishing an AML/CFT Commission.
However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Kyrgyzstan
should continue to work on implementing its action plan to address these deficiencies, including by:(1) adequately criminalising money laundering and terrorist financing; (2) establishing andimplementing an adequate legal framework for identifying, tracing and freezing terrorist assets; (3)4Improving Global AML/CFT Compliance: on-going process - 22 June 2012

establishing and implementing adequate measures for the confiscation of funds related to money
laundering; (4) establishing effective customer due diligence measures for all financial institutions;and (5) implementing an adequate and effective AML/CFT supervisory programme for all financial
sectors. The FATF encourages Kyrgyzstan to address its deficiencies and continue the process of
implementing its action plan, specifically enacting the necessary AML/CFT amendments.

Mongolia
In June 2011, Mongolia made a high-level political commitment to work with the FATF and APG toaddress its strategic AML/CFT deficiencies. Since February 2012, Mongolia has taken steps towards
improving its AML/CFT regime, including by strengthening operational coordination between the
FIU and law enforcement. However, the FATF has determined that strategic AML/CFT deficiencies
remain. Mongolia should continue to work on implementing its action plan to address these
deficiencies, including by: (1) adequately criminalising money laundering and terrorist financing; (2)establishing and implementing adequate procedures to identify and freeze terrorist assets; (3)establishing adequate procedures for the confiscation of funds related to money laundering; (4)establishing suspicious transaction reporting requirements; and (5) demonstrating effective
regulation of money service providers. The FATF encourages Mongolia to address its remaining
deficiencies and continue the process of implementing its action plan.

MoroccoIn February 2010, Morocco made a high-level political commitment to work with the FATF and
MENAFATF to address its strategic AML/CFT deficiencies. Since then, Morocco has demonstrated
progress in improving its AML/CFT regime, including by adopting amendments to extend the scopeof the money laundering and terrorist financing offences, to broaden customer due diligencerequirements and taking steps to operationalise the Financial Intelligence Unit. However, the FATF
has determined that certain strategic AML/CFT deficiencies remain. Morocco should continue towork on implementing its action plan to address these deficiencies, including by adequately
criminalising terrorist financing.

Namibia
In June 2011, Namibia made a high-level political commitment to work with the FATF and ESAAMLG
to address its strategic AML/CFT deficiencies. Namibia has taken steps towards improving its
AML/CFT regime, including ratifying the International Convention for the Suppression of Financingof Terrorism. However, the FATF has determined that certain strategic AML/CFT deficiencies
remain. Namibia should continue to work on implementing its action plan to address these
deficiencies, including by: (1) adequately criminalising terrorist financing; (2) establishing andimplementing adequate procedures to identify and freeze terrorist assets; (3) implementing anadequate AML/CFT supervisory programme with sufficient powers; (4) ensuring a fully operationaland effectively functioning Financial Intelligence Unit (FIU), in particular addressing the operational
autonomy of the FIU; and (5) implementing effective, proportionate and dissuasive sanctions inorder to deal with non-compliance with the national AML/CFT requirements. The FATF encourages
Namibia to address its remaining deficiencies and continue the process of implementing its action
plan.

5

Improving Global AML/CFT Compliance: on-going process - 22 June 2012

Nepal
In February 2010, Nepal made a high-level political commitment to work with the FATF and APG toaddress its strategic AML/CFT deficiencies. Since February 2012, Nepal enacted Mutual Legal
Assistance and Extradition Ordinances and issued directives related to the freezing of terrorist
assets and to financial institutions on customer due diligence. However, the FATF has determinedthat certain strategic AML/CFT deficiencies remain. Nepal should continue to work on implementing
its action plan to address these deficiencies, including by: (1) adequately criminalising money
laundering and terrorist financing; (2) establishing and implementing adequate procedures to
identify and freeze terrorist assets; (3) implementing adequate procedures for the confiscation offunds related to money laundering; (4) enacting and implementing appropriate mutual legal
assistance legislation; (5) ensuring a fully operational and effectively functioning Financial
Intelligence Unit; and (6) establishing adequate STR reporting obligations for ML and FT. The FATF
encourages Nepal to address its remaining deficiencies and continue the process of implementing its
action plan.

Nicaragua
In June 2011, Nicaragua made a high-level political commitment to work with the FATF and CFATF
to address its strategic AML/CFT deficiencies. However, the FATF has determined that certain
strategic AML/CFT deficiencies remain. Nicaragua should continue to work on implementing its
action plan to address these deficiencies, including by: (1) establishing effective customer due
diligence measures and record-keeping requirements, in particular entities not currently regulatedby the supervisory authority; (2) establishing adequate STR reporting obligations for ML and FT; (3)implementing an adequate AML/CFT supervisory programme for all financial sectors; (4) ensuring afully operational and effectively functioning Financial Intelligence Unit; and (5) establishingadequate procedures for identifying and freezing terrorist assets. The FATF encourages Nicaragua toaddress its remaining deficiencies, to continue the process of implementing its action plan.

Philippines
In October 2010, the Philippines made a high-level political commitment to work with the FATF and
APG to address its strategic AML/CFT deficiencies. Since February 2012, the Philippines has taken
significant steps to improve its AML/CFT system, including by enacting one of the amendments to
the AML Act and enacting a CFT Law. However, the FATF has determined that certain strategic
AML/CFT deficiencies remain. The Philippines should continue to work on implementing its action
plan to address these deficiencies, including by: (1) taking additional measures to adequately
criminalise money laundering; (2) ensuring adequate procedures to identify and freeze terrorist
assets and further expanding provisions regarding confiscation of funds related to money
laundering; and (3) extending coverage of reporting entities. The FATF encourages the Philippines toaddress its remaining deficiencies and continue the process of implementing its action plan. In
particular, the FATF strongly encourages the Philippines to enact the pending legislative amendment
on AML.

6

Improving Global AML/CFT Compliance: on-going process - 22 June 2012

Sudan
In February 2010, Sudan made a high-level political commitment to work with the FATF and
MENAFATF to address its strategic AML/CFT deficiencies. However, the FATF has determined thatcertain strategic AML/CFT deficiencies remain. Sudan should continue to work on implementing its
action plan to address these deficiencies, including by: (1) implementing adequate procedures for
identifying and freezing terrorist assets; (2) ensuring a fully operational and effectively functioning
Financial Intelligence Unit; and (3) ensuring an effective supervisory programme for AML/CFT
compliance. The FATF encourages Sudan to address its remaining deficiencies and continue theprocess of implementing its action plan.

Tajikistan
In June 2011, Tajikistan made a high-level political commitment to work with the FATF and EAG toaddress its strategic AML/CFT deficiencies. Since February 2012, Tajikistan has taken steps towards
improving its AML/CFT regime, including enhancing its financial intelligence unit and amending its
Criminal Code to improve its criminalisation of money laundering and terrorist financing. However,the FATF has determined that certain strategic AML/CFT deficiencies remain. Tajikistan should
continue to work on implementing its action plan to address these deficiencies, including by: (1)addressing remaining issues regarding criminalisation of money laundering and terrorist financing;(2) establishing and implementing adequate procedures for the confiscation of funds related tomoney laundering and identifying and freezing terrorist assets; (3) ensuring a fully operational, andeffectively functioning Financial Intelligence Unit and improving suspicious transaction reporting
requirements; and (4) improving and broadening customer due diligence measures. The FATF
encourages Tajikistan to address its remaining deficiencies and continue the process of
implementing its action plan.

Trinidad and Tobago
In February 2010, Trinidad and Tobago made a high-level political commitment to work with the
FATF and CFATF to address its strategic AML/CFT deficiencies. Since February 2012, Trinidad andTobago demonstrated progress in improving its AML/CFT regime, including by appointing apermanent director for its financial intelligence unit and adopting procedures to identify and freeze
terrorist assets. The FATF will conduct an on-site visit to confirm that the process of implementing
the required reforms and actions is underway to address deficiencies previously identified by the
FATF.

Venezuela
In October 2010, Venezuela made a high-level political commitment to work with the FATF and
CFATF to address its strategic AML/CFT deficiencies. Since then, Venezuela has taken steps towards
improving its AML/CFT regime, including by enacting AML/CFT legislation that criminalises
terrorist financing and establishes suspicious transaction reporting (STR) obligations for money
laundering and financing of terrorism, and issuing a new resolution aimed at addressing deficiencies
in the terrorist asset freezing regime. However, the FATF has determined that a strategic deficiency
remains. Venezuela should continue to work on implementing its action plan to address the7Improving Global AML/CFT Compliance: on-going process - 22 June 2012

remaining strategic deficiency, primarily by establishing and implementing adequate procedures to
identify and freeze terrorist assets. The FATF encourages Venezuela to address its remaining
deficiencies and continue the process of implementing its action plan.

Zimbabwe
In June 2011, Zimbabwe made a high-level political commitment to work with the FATF and
ESAAMLG to address its strategic AML/CFT deficiencies. The FATF has determined that strategic
AML/CFT deficiencies remain. Zimbabwe should continue to work on implementing its action plan toaddress these deficiencies, including by: (1) adequately criminalising money laundering andterrorist financing; (2) establishing and implementing adequate procedures to identify and freeze
terrorist assets; (3) ensuring a fully operational and effectively functioning Financial Intelligence
Unit; (4) ensuring that financial institutions are aware of and comply with their obligations to filesuspicious transaction reports in relation to money laundering and the financing of terrorism; (5)enacting and implementing appropriate mutual legal assistance legislation; and (6) implementing
the 1999 International Convention for the Suppression of Financing of Terrorism. The FATF
encourages Zimbabwe to address its remaining deficiencies and continue the process of
implementing its action plan.

**************************************************************************************

Turkmenistan
The FATF welcomes Turkmenistan’s significant progress in improving its AML/CFT regime andnotes that Turkmenistan has largely met its commitments in its Action Plan regarding the strategic
deficiencies that the FATF had identified. Turkmenistan is therefore no longer subject to FATF’s
monitoring process under its on-going global AML/CFT compliance process. Turkmenistan will workwith EAG as it continues to address the full range of AML/CFT issues identified in its Mutual
Evaluation Report, and further strengthen its AML/CFT regime.

8