RBI/2014-15/432
A.P. (DIR Series) Circular No.67
January 28, 2015
To,
All Authorised Persons, who are Indian Agents under Money Transfer Service
Scheme.
Madam/ Dear Sir,
Anti-Money Laundering (AML) standards/Combating the Financing of Terrorism (CFT)
Standards - Cross Border Inward Remittance under Money Transfer Service Scheme
Please refer to our
A.P.(DIR Series) Circular No.35 dated September 04, 2013 on
risks arising from the deficiencies in AML/CFT regime of certain jurisdictions.
- Financial Action Task Force (FATF) has updated its Statement on the
subject and document 'Improving Global AML/CFT Compliance: on-going process' on
October 24, 2014. The statement /document can be accessed from the following
URLs :
and
- Authorised Persons (Indian Agents) are accordingly advised to consider the
information contained in the enclosed statement.
- This, however, does not preclude Authorised Persons (Indian Agents) from
legitimate transactions with these countries and jurisdictions.
- These guidelines would also be applicable mutatis mutandis to all Sub-Agents
of the Indian Agents under MTSS and it will be the sole responsibility of the
APs (Indian Agents) to ensure that their Sub-agents also adhere to these
guidelines.
- Authorised Persons (Indian Agents) may bring the contents of this circular to
the notice of their constituents concerned.
- The directions contained in this Circular have been issued under Section
10(4) and Section 11(1) of the Foreign Exchange Management Act, 1999 (42 of
1999) and also under the, Prevention of Money Laundering Act, (PMLA), 2002, as
amended by Prevention of Money Laundering (Amendment) Act, 2009 and Prevention
of Money-Laundering (Maintenance of Records of the Nature and Value of
Transactions, the Procedure and Manner of Maintaining and Time for Furnishing
Information and Verification and Maintenance of Records of the Identity of the
Clients of the Banking Companies, Financial Institutions and Intermediaries)
Rules, 2005 as amended from time to time and are without prejudice to
permission/approvals, if any, required under any other law.
Yours faithfully,
(B P Kanungo)
Principal Chief General Manager
Improving Global AML/CFT Compliance: on-going process – 24 October 2014
Paris, 24 October 2014 - As part of its on-going review of compliance
with the AML/CFT standards, the FATF has to date identified the following
jurisdictions which have strategic AML/CFT deficiencies for which they have
developed an action plan with the FATF. While the situations differ among each
jurisdiction, each jurisdiction has provided a written high-level political
commitment to address the identified deficiencies. The FATF welcomes these
commitments.
A large number of jurisdictions have not yet been reviewed by the FATF. The FATF
continues to identify additional jurisdictions, on an on-going basis, that pose
a risk to the international financial system.
The FATF and the FATF-style regional bodies (FSRBs) will continue to work with
the jurisdictions noted below and to report on the progress made in addressing
the identified deficiencies. The FATF calls on these jurisdictions to complete
the implementation of action plans expeditiously and within the proposed
timeframes. The FATF will closely monitor the implementation of these action
plans and encourages its members to consider the information presented below.
Afghanistan
In June 2012, Afghanistan made a high-level political commitment to work with
the FATF and APG to address its strategic AML/CFT deficiencies. Since June 2014,
Afghanistan has taken steps towards improving its AML/CFT regime, including by
bringing CFT legislation into force and issuing CFT regulations. However, the
FATF has determined that certain strategic AML/CFT deficiencies remain.
Afghanistan should continue to work on implementing its action plan to address
its strategic AML/CFT deficiencies, including by: (1) adequately criminalising
money laundering and terrorist financing; (2) establishing and implementing an
adequate legal framework for identifying, tracing and freezing terrorist assets;
(3) implementing an adequate AML/CFT supervisory and oversight programme for all
financial sectors; (4) establishing and implementing adequate procedures for the
confiscation of assets related to money laundering; (5) establishing a fully
operational and effectively functioning financial intelligence unit; and (6)
establishing and implementing effective controls for cross-border cash
transactions. The FATF encourages Afghanistan to address its remaining
deficiencies and continue the process of implementing its action plan.
Albania
Since June 2012, when Albania made a high-level political commitment to work
with the FATF and MONEYVAL to address its strategic AML/CFT deficiencies,
Albania has made significant progress to improve its AML/CFT regime. Albania has
substantially addressed its action plan at a technical level, including by:
establishing adequate customer due diligence provisions; establishing an
adequate legal framework for identifying, tracing and freezing terrorist assets;
and enhancing the framework for international co-operation. The FATF will
conduct an on-site visit to confirm that the process of implementing the
required reforms and actions is underway to address deficiencies previously
identified by the FATF.
Angola
In June 2010 and again in February 2013 in view of its revised action plan,
Angola made a high-level political commitment to work with the FATF to address
its strategic AML/CFT deficiencies. Since June 2014, Angola has taken steps
towards improving its AML/CFT regime, including by commencing on-site
inspections of AML/CFT compliance by banks. However, the FATF has determined
that a strategic AML/CFT deficiency remains. Angola should continue to work on
implementing its action plan to address this deficiency by ensuring that
appropriate laws and procedures are in place to provide mutual legal assistance.
The FATF encourages Angola to address its remaining deficiency and continue the
process of implementing its action plan.
Cambodia
Since June 2011, when Cambodia made a high-level political commitment to work
with the FATF and APG to address its strategic AML/CFT deficiencies, Cambodia
has made significant progress to improve its AML/CFT regime. Cambodia has
substantially addressed its action plan at a technical level, including by:
adequately criminalising money laundering and terrorist financing; establishing
procedures to identify and freeze terrorist assets; establishing procedures for
the confiscation of funds related to money laundering; establishing an
effectively functioning financial intelligence unit; and establishing controls
for cross-border cash transactions. The FATF conducted an on-site visit but
cannot yet determine that implementation of the above reforms has begun. The
FATF encourages Cambodia to make progress by February 2015, when the FATF will
again assess the situation.
Guyana
In October 2014, Guyana made a high-level political commitment to work with the
FATF and CFATF to address its strategic AML/CFT deficiencies. Guyana will work
on implementing its action plan to address these deficiencies, including by: (1)
adequately criminalising money laundering and terrorist financing; (2)
establishing and implementing adequate procedures for the confiscation of assets
related to money laundering; (3) establishing and implementing an adequate legal
framework for identifying, tracing and freezing terrorist assets; (4)
establishing a fully operational and effectively functioning financial
intelligence unit; (5) establishing effective measures for customer due
diligence and enhancing financial transparency; (6) strengthening suspicious
transaction reporting requirements; and (7) implementing an adequate supervisory
framework. The FATF encourages Guyana to address its AML/CFT deficiencies by
implementing its action plan.
Iraq
In October 2013, Iraq made a high-level political commitment to work with the
FATF and MENAFATF to address its strategic AML/CFT deficiencies. The FATF has
determined that certain strategic AML/CFT deficiencies remain. Iraq 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 for
identifying, tracing and freezing terrorist assets; (3) establishing effective
customer due diligence measures; (4) establishing a fully operational and
effectively functioning financial intelligence unit; (5) establishing suspicious
transaction reporting requirements; and (6) establishing and implementing an
adequate AML/CFT supervisory and oversight programme for all financial sectors.
The FATF encourages Iraq to address its AML/CFT deficiencies by implementing its
action plan.
Kuwait
Since June 2012, when Kuwait made a high-level political commitment to work with
the FATF and MENAFATF to address its strategic AML/CFT deficiencies, Kuwait has
made significant progress to improve its AML/CFT regime. Kuwait has
substantially addressed its action plan at a technical level, including by:
adequately criminalising terrorist financing; establishing procedures to
identify and freeze terrorist assets; ensuring that appropriate laws and
procedures are in place to provide mutual legal assistance with respect to
terrorist financing; establishing customer due diligence measures; establishing
a financial intelligence unit; ensuring that financial institutions are
obligated to file suspicious transaction reports in relation to money laundering
and terrorist financing; and ratifying the Terrorist Financing Convention. The
FATF will conduct an on-site visit to confirm that the process of implementing
the required reforms and actions is underway to address deficiencies previously
identified by the FATF.
Lao PDR
In June 2013, the Lao PDR made a high-level political commitment to work with
the FATF and APG to address its strategic AML/CFT deficiencies. However, the
FATF has determined that certain strategic AML/CFT deficiencies remain. The Lao
PDR 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 adequate procedures for
the confiscation of assets related to money laundering; (3) establishing and
implementing an adequate legal framework for identifying, tracing and freezing
terrorist assets; (4) establishing a fully operational and effectively
functioning financial intelligence unit; (5) establishing suspicious transaction
reporting requirements; (6) implementing an adequate AML/CFT supervisory and
oversight programme for all financial sectors; and (7) establishing and
implementing effective controls for cross-border currency transactions. The FATF
encourages the Lao PDR to address its AML/CFT deficiencies and continue the
process of implementing its action plan.
Namibia
Since June 2011, when Namibia made a high-level political commitment to work
with the FATF and ESAAMLG to address its strategic AML/CFT deficiencies, Namibia
has made significant progress to improve its AML/CFT regime. Namibia has
substantially addressed its action plan at a technical level, including by:
adequately criminalising terrorist financing; establishing adequate procedures
to identify and freeze terrorist assets; ensuring that supervisory authorities
have sufficient powers to supervise for AML/CFT compliance; developing an
adequate AML/CFT supervisory programme; establishing a financial intelligence
unit; implementing effective, proportionate and dissuasive sanctions in order to
deal with non-compliance with the national AML/CFT requirements; and ratifying
the Terrorist Financing Convention. The FATF will conduct an on-site visit to
confirm that the process of implementing the required reforms and actions is
underway to address deficiencies previously identified by the FATF.
Nicaragua
Since June 2011, when Nicaragua made a high-level political commitment to work
with the FATF to address its strategic AML/CFT deficiencies, Nicaragua has made
significant progress to improve its AML/CFT regime. Nicaragua has substantially
addressed its action plan at a technical level, including by: establishing
effective customer due diligence measures and record-keeping requirements;
establishing suspicious transaction reporting requirements for money laundering
and terrorist financing; developing an AML/CFT supervisory programme for all
financial sectors; establishing a financial intelligence unit; and establishing
adequate procedures for identifying and freezing terrorist assets. The FATF will
conduct an on-site visit to confirm that the process of implementing the
required reforms and actions is underway to address deficiencies previously
identified by the FATF.
Pakistan
Since June 2010, when Pakistan made a high-level political commitment to work
with the FATF and APG to address its strategic AML/CFT deficiencies, Pakistan
has made significant progress to improve its AML/CFT regime. In June 2014, the
FATF determined that Pakistan had substantially addressed its action plan at a
technical level, including by: adequately criminalising money laundering and
terrorist financing; establishing procedures to identify, freeze and confiscate
terrorist assets; ensuring a fully operational and effectively functioning
financial intelligence unit; establishing regulation of money service providers;
and improving controls for cross-border cash transactions. Due to security
reasons, the FATF has been unable to conduct an on-site visit to assess whether
the process of implementing the required reforms and actions is underway. The
visit is currently scheduled to take place prior to the February 2015 FATF
meetings.
Panama
In June 2014, Panama made a high-level political commitment to work with the
FATF and GAFISUD to address its strategic AML/CFT deficiencies. However, the
FATF has determined that strategic AML/CFT deficiencies remain. Panama 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 for
freezing terrorist assets; (3) establishing effective measures for customer due
diligence in order to enhance transparency; (4) establishing a fully operational
and effectively functioning financial intelligence unit; (5) establishing
suspicious transaction reporting requirements for all financial institutions and
DNFBPs; and (6) ensuring effective mechanisms for international co-operation.
The FATF encourages Panama to address its AML/CFT deficiencies and continue the
process of implementing its action plan.
Papua New Guinea
In February 2014, Papua New Guinea made a high-level political commitment to
work with the FATF and APG to address its strategic AML/CFT deficiencies. Since
June, Papua New Guinea has taken steps towards improving its AML/CFT regime,
including by issuing prudential standards on customer due diligence. However,
the FATF has determined that strategic AML/CFT deficiencies remain. Papua New
Guinea 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 adequate procedures for
the confiscation of assets related to money laundering; (3) establishing and
implementing an adequate legal framework for identifying, tracing and freezing
terrorist assets; (4) establishing a fully operational and effectively
functioning financial intelligence unit; (5) establishing suspicious transaction
reporting requirements; (6) implementing an adequate AML/CFT supervisory and
oversight programme for all financial sectors; and (7) establishing and
implementing effective controls for cross-border currency transactions. The FATF
encourages Papua New Guinea to address its AML/CFT deficiencies and continue the
process of implementing its action plan.
Sudan
In February 2010 and again in June 2013 in view of its revised action plan,
Sudan made a high-level political commitment to work with the FATF and MENAFATF
to address its strategic AML/CFT deficiencies. Since June 2014, Sudan has taken
steps towards improving its AML/CFT regime, including by bringing into force
three decrees related to UNSCR asset freezing obligations. However, the FATF has
determined that strategic AML/CFT deficiencies remain. Sudan should continue to
work on implementing its action plan to address these deficiencies, including
by: (1) addressing the remaining issues regarding the predicate offences for
money laundering; (2) implementing adequate procedures for identifying and
freezing terrorist assets; (3) ensuring a fully operational and effectively
functioning financial intelligence unit; (4) improving customer due diligence
measures; and (5) ensuring that appropriate laws and procedures are in place
with regard to mutual legal assistance. The FATF encourages Sudan to address its
remaining deficiencies and continue the process of implementing its action plan.
Syria
Since February 2010, when Syria made a high-level political commitment to work
with the FATF and MENAFATF to address its strategic AML/CFT deficiencies, Syria
has made progress to improve its AML/CFT regime. In June 2014, the FATF
determined that Syria had substantially addressed its action plan at a technical
level, including by criminalising terrorist financing and establishing
procedures for freezing terrorist assets. While the FATF determined that Syria
has completed its action plan agreed upon with the FATF, due to the security
situation, the FATF has been unable to conduct an on-site visit to assess
whether the process of implementing the required reforms and actions is
underway. The FATF will continue to monitor the situation.
Uganda
In February 2014, Uganda made a high-level political commitment to work with the
FATF and ESAAMLG to address its strategic AML/CFT deficiencies. Since June 2014,
Uganda has taken steps towards improving its AML/CFT regime, including by
establishing its financial intelligence unit and issuing guidance to reporting
entities. However, the FATF has determined that strategic AML/CFT deficiencies
remain. Uganda should continue to work on implementing its action plan to
address these deficiencies, including by: (1) adequately criminalising terrorist
financing; (2) establishing and implementing an adequate legal framework for
identifying, tracing and freezing terrorist assets; (3) ensuring effective
record-keeping requirements; (4) establishing a fully operational and
effectively functioning financial intelligence unit; (5) ensuring adequate
suspicious transaction reporting requirements; (6) ensuring an adequate and
effective AML/CFT supervisory and oversight programme for all financial sectors;
and (7) ensuring that appropriate laws and procedures are in place with regard
to international co-operation for the financial intelligence unit and
supervisory authorities. The FATF encourages Uganda to address its remaining
AML/CFT deficiencies and continue the process of implementing its action plan.
Yemen
Since February 2010, when Yemen made a high-level political commitment to work
with the FATF and MENAFATF to address its strategic AML/CFT deficiencies, Yemen
has made progress to improve its AML/CFT regime. In June 2014, the FATF
determined that Yemen had substantially addressed its action plan at a technical
level, including by adequately criminalising money laundering and terrorist
financing; establishing procedures to identify and freeze terrorist assets;
improving its customer due diligence and suspicious transaction reporting
requirements; issuing guidance; developing the monitoring and supervisory
capacity of the financial sector supervisory authorities and the financial
intelligence unit (FIU); and establishing a fully operational and effectively
functioning FIU. While the FATF determined that Yemen has completed its action
plan agreed upon with the FATF, due to the security situation, the FATF has been
unable to conduct an on-site visit to assess whether the process of implementing
the required reforms and actions is underway. The FATF will continue to monitor
the situation.
Zimbabwe
Since June 2011, when Zimbabwe made a high-level political commitment to work
with the FATF and ESAAMLG to address its strategic AML/CFT deficiencies,
Zimbabwe has made significant progress to improve its AML/CFT regime. Zimbabwe
has substantially addressed its action plan at a technical level, including by:
adequately criminalising money laundering and terrorist financing; establishing
adequate procedures to identify and freeze terrorist assets; establishing a
financial intelligence unit; ensuring financial institutions are aware of and
comply with their obligations to file suspicious transaction reports in relation
to ML and FT; and ratifying the Terrorist Financing Convention. The FATF will
conduct an on-site visit to confirm that the process of implementing the
required reforms and actions is underway to address deficiencies previously
identified by the FATF.
Jurisdictions no longer subject to the FATF's on-going Global AML/CFT Compliance Process
Argentina
The FATF welcomes Argentina’s significant progress in improving its
AML/CFT regime and notes that Argentina has established the legal and
regulatory framework to meet its commitments in its action plan
regarding the strategic deficiencies that the FATF had identified in
June 2011. Argentina is therefore no longer subject to the FATF’s
monitoring process under its on-going global AML/CFT compliance process.
Argentina will work with the FATF and GAFISUD as it continues to address
the full range of AML/CFT issues identified in its mutual evaluation
report.
Cuba
The FATF welcomes Cuba’s significant progress in improving its
AML/CFT regime and notes that Cuba has established the legal and
regulatory framework to meet its commitments in its action plan
regarding the strategic deficiencies that the FATF had identified in
February 2013. Cuba is therefore no longer subject to the FATF’s
monitoring process under its on-going global AML/CFT compliance process.
Cuba will work with GAFISUD to further strengthen its AML/CFT regime.
Ethiopia
The FATF welcomes Ethiopia’s significant progress in improving its
AML/CFT regime and notes that Ethiopia has established the legal and
regulatory framework to meet its commitments in its action plan
regarding the strategic deficiencies that the FATF had identified in
June 2010. Ethiopia is therefore no longer subject to the FATF’s
monitoring process under its on-going global AML/CFT compliance process.
Ethiopia will work with ESAAMLG to further strengthen its AML/CFT
regime.
Tajikistan
The FATF welcomes Tajikistan’s significant progress in improving its
AML/CFT regime and notes that Tajikistan has established the legal and
regulatory framework to meet its commitments in its action plan
regarding the strategic deficiencies that the FATF had identified in
June 2011. Tajikistan is therefore no longer subject to the FATF’s
monitoring process under its on-going global AML/CFT compliance process.
Tajikistan will work with EAG as it continues to address the full range
of AML/CFT issues identified in its mutual evaluation report.
Turkey
The FATF welcomes Turkey’s significant progress in improving its
AML/CFT regime and notes that Turkey has established the legal and
regulatory framework to meet its commitments in its action plan
regarding the strategic deficiencies that the FATF had identified in
February 2010. Turkey is therefore no longer subject to the FATF’s
monitoring process under its on-going global AML/CFT compliance process.
Turkey will work with the FATF as it continues to address the full range
of AML/CFT issues identified in its mutual evaluation report.
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Public Statement - 24 October 2014
Paris, 24 October 2014 - The Financial Action Task Force (FATF) is the
global standard setting body for anti-money 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 and works 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 to protect the international financial system from
the on-going and substantial money laundering and terrorist
financing (ML/FT) risks emanating from the jurisdictions.
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Iran
Democratic People’s Republic of Korea (DPRK)
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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 associated with each jurisdiction, as described below.
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Algeria
Ecuador
Indonesia
Myanmar
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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 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. The FATF continues to urge
jurisdictions to protect against correspondent relationships being used
to bypass or evade counter-measures and risk mitigation practices and to
take into account ML/FT risks when considering requests by Iranian
financial 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 by criminalising terrorist financing
and effectively implementing suspicious transaction reporting
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
2015.
Democratic People's Republic of Korea (DPRK)
Since June 2014, the DPRK has further engaged directly with the FATF
and APG to discuss its AML/CFT deficiencies. The FATF urges the DPRK to
continue its cooperation with the FATF and to provide a high-level
political commitment to the action plan developed with the FATF.
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 to the 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 their financial 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 calls 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 the DPRK. Jurisdictions should also protect
against correspondent relationships being used to bypass or evade
counter-measures and risk mitigation practices, and take into account
ML/FT risks when considering requests by DPRK financial institutions to
open branches and subsidiaries in their jurisdiction.
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Algeria
Algeria has taken steps towards improving its AML/CFT regime. However, despite
Algeria’s high-level political commitment to work with the FATF and MENAFATF to
address its strategic AML/CFT deficiencies, Algeria has not made sufficient
progress in implementing its action plan within the established timelines, and
certain strategic deficiencies remain. Algeria should continue to work on
implementing its action plan to address these deficiencies, including by: (1)
adequately criminalising terrorist financing; (2) establishing and implementing
an adequate legal framework for identifying, tracing and freezing terrorist
assets and (3) adopting customer due diligence obligations in compliance with
the FATF Standards. The FATF encourages Algeria to address its remaining
deficiencies and continue the process of implementing its action plan.
Ecuador
Ecuador has taken steps towards improving its AML/CFT regime including by
issuing AML/CFT regulations for companies supervised by Superintendence of
Companies. However, 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, and certain
strategic deficiencies remain. Ecuador should continue to work on implementing
its action plan to address these deficiencies, including by (1) establishing and
implementing adequate procedures to identify and freeze terrorist assets and (2)
clarifying procedures for the confiscation of funds related to money laundering.
Ecuador should also continue enhancing financial sector supervision. The FATF
encourages Ecuador 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 including by
further implementing its terrorist asset-freezing regime. However, despite
Indonesia’s high-level political commitment to work with the FATF and APG to
address its strategic CFT deficiencies, Indonesia has not made sufficient
progress in implementing its action plan within the agreed timelines, and
certain key CFT deficiencies remain regarding the development and implementation
of an adequate legal framework and procedures for identifying and freezing of
terrorist assets. The FATF encourages Indonesia to address its remaining
deficiencies in compliance with FATF standards by fully implementing UNSCR 1267
and improving the legal framework and procedures for freezing terrorist assets.
Myanmar
Myanmar has taken steps towards improving its AML/CFT regime. However, despite
Myanmar’s high-level political commitment to work with the FATF and APG to
address 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 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; (3) further strengthening the extradition
framework in relation to terrorist financing; (4) ensuring a fully operational
and effectively functioning financial intelligence unit; (5) enhancing financial
transparency; and (6) strengthening customer due diligence measures. The FATF
encourages Myanmar to address the remaining deficiencies and continue the
process of implementing its action plan.
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