AML/CFT - Country lists update

The Authority wishes to draw your attention to a number of amendments to the various country lists following the October 2021 FATF Plenary and the most recent publication of the FATF’s consolidated table of 4^th round assessment ratings. The country lists have been amended by the Cabinet Office and can be viewed on the DHA’s website.

If not already undertaken, Regulated or supervised entities should carry out their own evaluation for any potential impact on their risk assessments and procedures, arising from the changes.

In particular the Authority would like to highlight that the USA and South Africa have been removed from List C (Equivalent jurisdiction list). A revision of List B (ii) (Jurisdictions that may pose a higher risk of money laundering or terrorist financing) in September 2021 determined that the USA, as a result of several instances of domestic terrorism in the past 12 months, was now considered a jurisdiction that may pose a higher risk of terrorist financing. In addition, following the FATF’s adoption of its 4^th round mutual evaluation report in October 2021, South Africa’s AML/CFT regime has been assessed as being deficient in 20 of the 40 FATF recommendations, including recommendation `10 – Customer Due Diligence’. Consequently, both jurisdictions now no longer meet the requirements of the methodology for List C.

It is requested that any licence holders or registered persons with business relationships/customers connected to the aforementioned jurisdictions provide the Authority with details of those business relationships highlighting whether simplified measures have been used, and if so, explaining which measures.  These details should be provided to aml@iomfsa.im by the end of December 2021.