Countries where FATF has called for counter measures remains unchanged with both North Korea and Iran still listed. That said counter measures on Iran had been suspended and that suspension was continued but only for a short period.. FATF made clear that, “if by June 2019, Iran does not enact the remaining legislation in line with FATF Standards, then the FATF will require increased supervisory examination for branches and subsidiaries of financial institutions based in Iran. The FATF also expects Iran to continue to progress with enabling regulations and other amendments.”

Notwithstanding the continued suspension of “counter measures” FATF remains “concerned with the terrorist financing risk emanating from Iran and the threat this poses to the international financial system” and FATF calls on its members “and urges all jurisdictions to continue to advise their financial institutions to apply enhanced due diligence with respect to business relationships and transactions with natural and legal persons from Iran, consistent with FATF Recommendation 19, including: (1) obtaining information on the reasons for intended transactions; and (2) conducting enhanced monitoring of business relationships, by increasing the number and timing of controls applied, and selecting patterns of transactions that need further examination.” – in other words still don’t Bank and or don’t onboard Iranian domiciled FI’s, appears to be the message.

As part of its ongoing review of compliance with FATF standards, the following Countries are listed as having strategic AML/CFT deficiencies albeit with action plans to address the identified deficiencies. These are: Bahamas; Botswana; Cambodia; Ethiopia; Ghana; Pakistan; Serbia; Sri Lanka; Syria; Trinidad and Tobago; Tunisia & Yemen. This list should not be seen as conclusive as FAFT recognise not all Countries have been reviewed in this round so this list could change as reviews are completed.