FATF STATEMENT CONCERNING IRAN, UZBEKISTAN, TURKMENISTAN,PAKISTAN, AND SÃO TOMÉ AND PRÍNCIPEIRANThe FATF is concerned by Iran’s lack of engagement with the FATF and its failure tomeaningfully address the ongoing and substantial deficiencies in its anti-money
laundering and combating the financing of terrorism (AML/CFT) regime. The FATF
remains particularly concerned about Iran’s failure to address the risk of terrorist
financing and the serious threat this poses to the integrity of the international financialsystem. The FATF urges Iran to immediately and meaningfully address its AML/CFT
deficiencies, in particular by criminalising terrorist financing and effectively
implementing suspicious transaction reporting (STR) requirements.
The FATF reaffirms its call on members and urges all jurisdictions to advise theirfinancial institutions to give special attention to business relationships andtransactions with Iran, including Iranian companies and financial institutions. In
addition to enhanced scrutiny, the FATF reaffirms its 25 February 2009 call on its
members and urges all jurisdictions to apply effective counter-measures to protect
their financial sectors from money laundering and financing of terrorism (ML/FT) risks
emanating from Iran. FATF continues to urge jurisdictions to protect against
correspondent relationships being used to bypass or evade counter-measures andrisk mitigation practices, and to take into account ML/FT risks when considering
requests by Iranian financial institutions to open branches and subsidiaries in theirjurisdiction. If Iran fails to take concrete steps to improve its AML/CFT regime, theFATF will consider calling on its members and urging all jurisdictions to strengthencounter-measures in February 2010.

UZBEKISTANThe FATF welcomes the significant steps that Uzbekistan has taken to establish thenecessary AML/CFT framework and urges Uzbekistan to continue its progress towards
implementing effective AML/CFT measures. The FATF welcomes Uzbekistan’s
upcoming mutual evaluation by the EAG that will be finalized in spring 2010. The
FATF will continue to monitor the progress being made in Uzbekistan and willreconsider in February 2010 the measures that are currently in place to protect
jurisdictions’ financial sectors from ML/FT risks emanating from Uzbekistan.

TURKMENISTANThe FATF welcomes Turkmenistan’s progress in adopting AML/CFT legislation andsecondary legislation that aims to implement the AML/CFT law. However,deficiencies remain in Turkmenistan’s AML/CFT regime, including the absence of a
Financial Intelligence Unit (FIU). Consequently, the FATF reiterates its 25 February
2009 statement informing financial institutions that these deficiencies constitute an
ML/FT vulnerability in the international financial system and that they should takeappropriate measures to address this risk. Turkmenistan is urged to continue to takesteps to implement an AML/CFT regime that meets international AML/CFT standards.
Turkmenistan is encouraged to continue to work closely with the Eurasian Group andthe International Monetary Fund to achieve this.

PAKISTAN
The FATF welcomes the close co-operation between Pakistan and the Asia/PacificGroup on Money Laundering (APG), but remains concerned regarding the ML/FT risks
posed by Pakistan and reaffirms its public statement of 28 February 2008 regardingthese risks. In particular, the FATF expresses concern that Pakistan’s Anti-Money
Laundering Ordinance (AMLO) will expire on 28 November 2009. The FATF notes thatPakistan has initiated a legislative process to address this. The FATF strongly urges
Pakistan to implement a permanent AML/CFT framework before the expiration of theAMLO and strongly encourages Pakistan to establish a comprehensive AML/CFTframework. Failing concrete progress, the FATF will consider taking action inFebruary 2010 to protect the financial system from the ML/FT risks emanating fromPakistan.

SÃO TOMÉ AND PRÍNCIPEThe FATF welcomes São Tomé and Príncipe’s continuing efforts to implement its AML
law, including the development of an action plan with the Inter Governmental Action
Group against Money Laundering in West Africa (GIABA). However, the FATF remains
concerned about the deficiencies in São Tomé and Príncipe’s AML/CFT regime,
particularly relating to terrorist financing. The FATF urges São Tomé and Príncipe towork with GIABA to address the remaining AML/CFT deficiencies.