FinCEN Advisory on High-Risk Customers

On September 21, 2018, FinCEN released an advisory on the FATF-identified jurisdictions with AML/CFT deficiencies.   This advisory, known as FIN-2018-A004, relays information to US financial institutions regarding countries the Financial Action Task Force (FATF) has identified as having deficiencies.  

FATF is an intergovernmental body comprised of 37 nations that work together to create uniform anti-money laundering standards.  When countries don’t meet their standards, FATF communicates deficient countries to the FinCEN, who then provides communication to financial institutions.

This current advisory removed Iraq and Vanuatu from the sanctions II list but added Pakistan to the list due to identified deficiencies.  All other countries currently on the list - such as Sanction I countries of Iran and the Democratic People’s Republic of Korea and Sanction II countries Ethiopia, Serbia, Sri Lanka, Syria, Trinidad & Tobago, Tunisia, and Yemen - were unchanged.

The full advisory can be found here.  

A Checklist of TRID 2.0 Changes

Federal Reserve Board Proposes Repeal of S.A.F.E. Act Regulations