On November 18, 2010, the Financial CrimesEnforcement Network (“FinCEN”), issued an advisory(“Advisory”) to inform banks and other financialinstitutions operating in the United States of the risksassociated with jurisdictions identified by the FinancialAction Task Force (“FATF”) on October 22, 2010(“Public Statement”), as having strategic deficienciesin their anti-money laudenring (“AML”) and counterterroristfinancing (“CFT”) regimes.
In the Public Statement, FATF identified certainjurisdictions as having strategic AML/CFT deficienciesfor which they have developed an action plan with theFATF. These jurisdictions include the following in ourhemisphere: Antigua and Barbuda, Bolivia, Ecuador,Honduras, Paraguay, Trinidad and Tobago, andVenezuela. FinCEN advises U.S. financial institutionsto consider the risks associated with the AML/CFTdeficiencies of these jurisdictions and comply with thegeneral due diligence obligations under 31 CFR §103.17(a) (future 31 CFR. §1010.610(a)).Please note that a large number of jurisdictions havenot yet been reviewed by the FATF. FATF continuesto identify additional jurisdictions that pose a risk inthe international financial system. The next statementis expected to be presented next year.
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