High-risk and non-cooperative jurisdictions
FATF PUBLIC STATEMENT - 19 October 2012
Paris, 19 October 2012 - The Financial Action Task Force (FATF) is the global standard setting body for antimoney laundering and combating the financing of terrorism (AML/CFT). In order to protect the international
financial system from money laundering and financing of terrorism (ML/FT) risks and to encourage greater
compliance with the AML/CFT standards, the FATF identified jurisdictions that have strategic deficiencies andworks with them to address those deficiencies that pose a risk to the international financial system.
Jurisdictions subject to a FATF call on its members and other jurisdictions to apply counter-measures toprotect the international financial system from the on-going and substantial money laundering andterrorist financing (ML/TF) risks emanating from the jurisdictions.
Iran
Democratic People's Republic of Korea (DPRK)
Jurisdictions with strategic AML/CFT deficiencies that have not made sufficient progress in addressing
the deficiencies or have not committed to an action plan developed with the FATF to address the
deficiencies. The FATF calls on its members to consider the risks arising from the deficiencies associatedwith each jurisdiction, as described below.
Bolivia
Cuba
Ecuador
EthiopiaIndonesia
Kenya
MyanmarNigeria
PakistanSão Tomé and Príncipe
Sri Lanka
Syria
Tanzania
ThailandTurkey*Vietnam
Yemen* See the below text on Turkey

Iran
The FATF remains particularly and exceptionally concerned about Iran’s failure to address the risk of terrorist
financing and the serious threat this poses to the integrity of the international financial system, despite Iran’s
previous engagement with the FATF and recent submission of information.
The FATF reaffirms its call on members and urges all jurisdictions to advise their financial institutions to give
special attention to business relationships and transactions with Iran, including Iranian companies andfinancial institutions. In addition to enhanced scrutiny, the FATF reaffirms its 25 February 2009 call on its

FATF Public Statement – 19 October 2012

members and urges all jurisdictions to apply effective counter-measures to protect their financial sectors frommoney 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-measuresand risk mitigation practices and to take into account ML/FT risks when considering requests by Iranianfinancial institutions to open branches and subsidiaries in their jurisdiction. Due to the continuing terrorist
financing threat emanating from Iran, jurisdictions should consider the steps already taken and possible
additional safeguards or strengthen existing ones.
The FATF urges Iran to immediately and meaningfully address its AML/CFT deficiencies, in particular bycriminalising terrorist financing and effectively implementing suspicious transaction reporting (STR)
requirements. If Iran fails to take concrete steps to continue to improve its CFT regime, the FATF will consider
calling on its members and urging all jurisdictions to strengthen counter-measures in February 2013.

Democratic 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 threat this poses tothe integrity of the international financial system. The FATF urges the DPRK to immediately and meaningfully
address its AML/CFT deficiencies.
The FATF reaffirms its 25 February 2011 call on its members and urges all jurisdictions to advise theirfinancial institutions to give special attention to business relationships and transactions with the DPRK,
including DPRK companies and financial institutions. In addition to enhanced scrutiny, the FATF further callson 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 the DPRK. Jurisdictions
should also protect against correspondent relationships being used to bypass or evade counter-measures andrisk mitigation practices, and take into account ML/FT risks when considering requests by DPRK financial
institutions to open branches and subsidiaries in their jurisdiction.
The FATF remains prepared to engage directly in assisting the DPRK to address its AML/CFT deficiencies.
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Bolivia
Bolivia has taken steps towards improving its AML/CFT regime, including by enacting new legislation to
substantially address the deficiencies in the criminalisation of money laundering and terrorist financing andworking towards strengthening the capacity and autonomy of the FIU. However, despite Bolivia’s high-level
political commitment to work with the FATF and GAFISUD to address its strategic AML/CFT deficiencies,
Bolivia has not made sufficient progress in implementing its action plan within the established timelines.
Bolivia should continue to work on addressing the remaining issue of enhancing the legal framework for
identifying and freezing terrorist assets. The FATF encourages Bolivia to address its remaining deficiency andcontinue the process of implementing its action plan.

Cuba
In June 2011, the FATF identified Cuba as having strategic AML/CFT deficiencies and it had not engaged with
the FATF. Since then, Cuba has significantly enhanced its engagement and co-operation with the FATF andmade a request to join GAFISUD. However, the FATF urges Cuba to continue its engagement with the FATF andto work with the FATF to develop and agree on an action plan in order to address its AML/CFT deficiencies.

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FATF Public Statement – 19 October 2012

EcuadorEcuador has taken steps towards improving its AML/CFT regime, including by tabling CFT legislation in
Parliament. Despite Ecuador’s high-level political commitment to work with the FATF and GAFISUD to address
its strategic AML/CFT deficiencies, Ecuador has not made sufficient progress in implementing its action plan
within the established timelines, and certain strategic deficiencies remain. Ecuador should continue to workwith the FATF and GAFISUD on implementing its action plan to address these deficiencies, including by: (1)ensuring adequate criminalisation of terrorist financing; (2) establishing and implementing adequate
procedures to identify and freeze terrorist assets; (3) implementing adequate procedures for the confiscationof funds related to money laundering; and (4) continue to enhancing co-ordination of financial sector
supervision. The FATF encourages Ecuador to address its remaining deficiencies, including by enacting CFTlegislation, and continue the process of implementing its action plan.

Ethiopia
Ethiopia has taken steps towards improving its AML/CFT regime, including by building up its Financial
Intelligence Unit. However, despite Ethiopia’s high-level political commitment to work with the FATF to
address its strategic AML/CFT deficiencies, Ethiopia has not made sufficient progress in implementing its
action plan, and certain strategic AML/CFT deficiencies remain. Ethiopia 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 an adequate legal framework andprocedures to identify and freeze terrorist assets; (3) ensuring a fully operational and effectively functioning
Financial Intelligence Unit; and (4) implementing effective, proportionate and dissuasive sanctions in order todeal with natural or legal persons that do not comply with the national AML/CFT requirements. The FATF
encourages Ethiopia to address its remaining deficiencies and continue the process of implementing its action
plan.

Indonesia
Indonesia has taken steps towards improving its AML/CFT regime. However, despite Indonesia’s high-level
political commitment to work with the FATF and APG to address its strategic AML/CFT deficiencies, Indonesia
has not made sufficient progress in implementing its action plan, and certain strategic AML/CFT deficiencies
remain. Indonesia should continue to work on implementing its action plan to address these deficiencies,
including by: (1) adequately criminalising terrorist financing; (2) establishing and implementing adequate
procedures to identify and freeze terrorist assets; and (3) amending and implementing laws or other
instruments to fully implement the Terrorist Financing Convention. The FATF encourages Indonesia to address
its remaining deficiencies, particularly by passing adequate CFT legislation, and continue the process of
implementing its action plan.

Kenya
Kenya has taken significant steps towards improving its AML/CFT regime, including the enactment of thePrevention of Terrorism Act and the Capital Market (Amendment) Bill and the passage by Parliament of theProceeds of Crime and Anti-Money Laundering (Amendment) Act and the Finance Bill. The FATF has not yetassessed these laws due to their very recent nature, and therefore the FATF could not determine the extent towhich they address any of the following issues: (1) adequately criminalising money laundering and terrorist
financing; (2) ensuring a fully operational and effectively functioning Financial Intelligence Unit; (3)establishing and implementing an adequate legal framework for the confiscation of funds related to money
laundering, and the identification and freezing of terrorist assets; (4) implementing effective, proportionate
and dissuasive sanctions in order to deal with natural or legal persons that do not comply with the national
AML/CFT requirements; (5) implementing an adequate and effective AML/CFT supervisory programme for all3

FATF Public Statement – 19 October 2012financial sectors; (6) enhancing financial transparency; (7) further improving and broadening customer due
diligence measures; and (8) establishing adequate record-keeping requirements. Despite Kenya’s high-level
political commitment to work with the FATF and ESAAMLG to address its strategic AML/CFT deficiencies,
Kenya has not made sufficient progress in implementing its action plan within the agreed timelines, andcertain strategic AML/CFT deficiencies may remain. The FATF encourages Kenya to address its remaining
deficiencies and continue the process of implementing its action plan.

Myanmar
Myanmar has taken steps towards improving its AML/CFT regime, including by removing its reservations to
the extradition articles of the Vienna Convention, the Palermo Convention and the Terrorist Financing
Convention. However, despite Myanmar’s high-level political commitment to work with the FATF and APG toaddress its strategic AML/CFT deficiencies, Myanmar has not made sufficient progress in implementing its
action plan, and certain strategic AML/CFT deficiencies remain. Myanmar should work on implementing its
action plan to address these deficiencies, including by: (1) adequately criminalising terrorist financing;(2) establishing and implementing adequate procedures to identify and freeze terrorist assets; (3) further
strengthening the extradition framework in relation to terrorist financing; (4) ensuring a fully operational andeffectively functioning Financial Intelligence Unit; (5) enhancing financial transparency; and (6) strengthening
customer due diligence measures. The FATF encourages Myanmar to address the remaining deficiencies andcontinue the process of implementing its action plan.

Nigeria
Nigeria has taken steps towards improving its AML/CFT regime, including by the adoption by Parliament ofboth the Money Laundering (Prohibition) Amendment Bill and the Terrorism (Prevention) Amendment Bill.
The FATF has not yet assessed these laws due to their very recent nature, and therefore the FATF could not
determine the extent to which they address Nigeria’s two remaining issues regarding criminalisation of money
laundering and terrorist financing. The FATF encourages Nigeria to address its remaining deficiencies andcontinue the process of implementing its action plan.

Pakistan
Pakistan has taken significant steps towards improving its AML/CFT regime, including introducing CFT
amendments into Parliament. However, despite Pakistan’s high-level political commitment to work with the
FATF and APG to address its strategic AML/CFT deficiencies, Pakistan has not yet made sufficient progress infully implementing its action plan, and certain key CFT deficiencies remain. Specifically, Pakistan needs toenact legislation to ensure that it meets the FATF standards regarding the terrorist financing offence and theability to identify, freeze, and confiscate terrorist assets. The FATF encourages Pakistan to address theremaining deficiencies and continue the process of implementing its action plan.

São Tomé and Príncipe
Despite São Tomé and Príncipe’s high-level political commitment to work with the FATF and GIABA to address
its strategic AML/CFT deficiencies, São Tomé and Príncipe has not made sufficient progress in implementing
its action plan, and certain strategic deficiencies remain. São Tomé and Príncipe 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 a fully operational and effectively functioning Financial
Intelligence Unit; (3) ensuring that financial institutions and DNFBPs are subject to adequate AML/CFT
regulation and supervision; and (4) implementing effective, proportionate and dissuasive sanctions in order todeal with natural or legal persons that do not comply with the national AML/CFT requirements. The FATF

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FATF Public Statement – 19 October 2012encourages São Tomé and Príncipe to address its remaining deficiencies and continue the process of
implementing its action plan.

Sri Lanka
Sri Lanka has taken significant steps towards improving its AML/CFT regime. However, despite Sri Lanka’shigh-level political commitment to work with the FATF and APG to address its strategic AML/CFT deficiencies,
Sri Lanka has not made sufficient progress in implementing its action plan. Sri Lanka should continue to workon addressing the remaining issue regarding adequate criminalisation of terrorist financing. The FATF
encourages Sri Lanka to address this deficiency and continue the process of implementing its action plan.

Syria
Previously, Syria had taken significant steps towards improving its AML/CFT regime. However, despite Syria’s
high-level political commitment to work with the FATF and MENAFATF to address its strategic AML/CFT
deficiencies, Syria has not made sufficient progress in implementing its action plan, and certain strategic
AML/CFT deficiencies remain. Syria should continue to work on implementing its action plan to address these
deficiencies, including by: (1) providing sufficient legal basis for implementing the obligations under UNSCR
1373 and implementing adequate procedures for identifying and freezing terrorist assets; and (2) ensuringthat appropriate laws and procedures are in place to provide mutual legal assistance. The FATF encourages
Syria to demonstrate that its remaining deficiencies have been addressed to enable the FATF to properly
evaluate Syria’s progress.

Tanzania
Tanzania has taken steps towards improving its AML/CFT regime, including enactment of amendments to theAnti-Money Laundering Act and the Prevention of Terrorism Act as well as the issuance of implementing
regulations which expand on requirements related to customer due diligence and recordkeeping and provide
for an operational independent national Financial Intelligence Unit. However, despite Tanzania’s high-level
political commitment to work with the FATF and ESAAMLG to address its strategic AML/CFT deficiencies,
Tanzania has not made sufficient progress in implementing its action plan within the agreed timelines, andcertain strategic AML/CFT deficiencies remain. Tanzania should continue to work on implementing its action
plan to address these deficiencies, including by: (1) clarifying the remaining issues regarding the predicate
offences for money laundering and criminalisation of terrorist financing; (2) establishing and implementing
adequate procedures to identify and freeze terrorist assets as well as implementing the UNSCRs 1267 and1373 through law, regulations or other enforceable means. The FATF encourages Tanzania to address its
remaining deficiencies, including ratifying the Terrorist Financing Convention, and continue the process of
implementing its action plan.

ThailandThailand has taken steps towards improving its AML/CFT regime, including by issuing customer due diligence
regulations. However, despite Thailand’s high-level political commitment to work with the FATF and APG toaddress its strategic AML/CFT deficiencies, Thailand has not made sufficient progress in implementing its
action plan, and certain strategic AML/CFT deficiencies remain, although Thailand has faced externaldifficulties from 2009 to 2011 which significantly impacted the legislative process for the necessary laws andregulations. Thailand should continue to work on implementing its action plan to address the remaining
deficiencies, including by: (1) adequately criminalising terrorist financing; (2) establishing and implementing
adequate procedures to identify and freeze terrorist assets; and (3) further strengthening AML/CFT
supervision. The FATF encourages Thailand to address its remaining deficiencies and continue the process of
implementing its action plan, specifically enacting its draft CFT legislation.

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FATF Public Statement – 19 October 2012

Turkey*Despite Turkey’s high-level political commitment to work with the FATF to address its strategic CFT
deficiencies, Turkey has not made sufficient progress in implementing its action plan, and certain strategic CFT
deficiencies remain. Turkey should work on addressing these deficiencies, including by: (1) adequately
criminalising terrorist financing; and (2) implementing an adequate legal framework for identifying andfreezing terrorist assets. Given Turkey’s continued lack of progress in these two areas, as a counter-measure,
the FATF has decided to suspend Turkey’s membership on 22 February 2013 unless the following conditions
are met before that date: (1) Turkey adopts legislation to adequately remedy deficiencies in its terrorist
financing offence; and (2) Turkey establishes an adequate legal framework for identifying and freezing
terrorist assets consistent with the FATF Recommendations. FATF calls upon countries to take additional steps
as necessary proportionate to the risks arising from the deficiencies associated with Turkey.

VietnamVietnam has taken steps towards improving its AML/CFT regime. However, despite Vietnam’s high-level
political commitment to work with the FATF and APG to address its strategic AML/CFT deficiencies, Vietnam
has not made sufficient progress in implementing its action plan, and certain strategic AML/CFT deficiencies
remain. Vietnam should continue to work with the FATF and APG on implementing its action plan to addressthese deficiencies, including by: (1) address the remaining issues regarding adequate criminalisation ofterrorist financing; (2) establishing and implementing adequate procedures to identify and freeze terrorist
assets; (3) making legal persons subject to criminal liability in line with FATF Standards or demonstrating that
there is a constitutional prohibition that prevents this; (4) improving the overall supervisory framework); (5)improving and broadening customer due diligence measures and reporting requirements; and (6)strengthening international co-operation. The FATF encourages Vietnam to address its remaining deficiencies
and continue the process of implementing its action plan.

Yemen
Despite Yemen’s high-level political commitment to work with the FATF and MENAFATF to address its
strategic AML/CFT deficiencies, Yemen has not made sufficient progress in implementing its action plan andcertain strategic AML/CFT deficiencies remain. Yemen should continue to work on implementing its action
plan to address these deficiencies, including by: (1) adequately criminalizing money laundering and terrorist
financing; (2) establishing and implementing adequate procedures to identify and freeze terrorist assets; (3)developing the monitoring and supervisory capacity of the financial sector supervisory authorities and the
Financial Intelligence Unit (FIU) to ensure compliance by financial institutions with their suspicioustransaction reporting obligations, especially in relation to the financing of terrorism; and (4) ensuring a fully
operational and effectively functioning FIU. The FATF encourages Yemen to address its remaining deficiencies
and continue the process of implementing its action plan.
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Ghana
Pursuant to Ghana’s progress in largely addressing its action plan agreed upon with the FATF, Ghana is now
identified in the FATF’s separate but related public document, “Improving Global AML/CFT Compliance: Ongoing Process.”

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