Paris, 19 October 2012 - 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/TF) risks emanating from the jurisdictions.

Iran
Democratic People's Republic of Korea (DPRK)

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.

Bolivia
Cuba
Ecuador
Ethiopia
Indonesia
Kenya
Myanmar
Nigeria
Pakistan
São Tomé and Príncipe
Sri Lanka
Syria
Tanzania
Thailand
Turkey*
Vietnam
Yemen

* See the below text on Turkey

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. 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 (STR) 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 2013.

Democratic People's Republic of Korea (DPRK)

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.

The FATF remains prepared to engage directly in assisting the DPRK to address its AML/CFT deficiencies.

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Bolivia

Bolivia has taken steps towards improving its AML/CFT regime, including by enacting new legislation to substantially address the deficiencies in
the criminalisation of money laundering and terrorist financing and working towards strengthening the capacity and autonomy of the FIU.
However, despite Bolivia’s high-level political commitment to work with the FATF and GAFISUD to address its strategic AML/CFT deficiencies,
Bolivia has not made sufficient progress in implementing its action plan within the established timelines. Bolivia should continue to work on
addressing the remaining issue of enhancing the legal framework for identifying and freezing terrorist assets. The FATF encourages Bolivia to
address its remaining deficiency and continue the process of implementing its action plan.

Cuba

In June 2011, the FATF identified Cuba as having strategic AML/CFT deficiencies and it had not engaged with the FATF. Since then, Cuba has
significantly enhanced its engagement and co-operation with the FATF and made a request to join GAFISUD. However, the FATF urges Cuba to
continue its engagement with the FATF and to work with the FATF to develop and agree on an action plan in order to address its AML/CFT
deficiencies.

Ecuador

Ecuador has taken steps towards improving its AML/CFT regime, including by tabling CFT legislation in Parliament. 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 within the established timelines, and certain strategic deficiencies remain. Ecuador should continue to
work with the FATF and GAFISUD on implementing its action plan to address these deficiencies, including by: (1) ensuring adequate
criminalisation of terrorist financing; (2) establishing and implementing adequate procedures to identify and freeze terrorist assets; (3)
implementing adequate procedures for the confiscation of funds related to money laundering; and (4) continue to enhancing co-ordination of
financial sector supervision. The FATF encourages Ecuador to address its remaining deficiencies, including by enacting CFT legislation, and
continue the process of implementing its action plan.

Ethiopia

Ethiopia has taken steps towards improving its AML/CFT regime, including by building up its Financial Intelligence Unit. However, despite
Ethiopia’s high-level political commitment to work with the FATF to address its strategic AML/CFT deficiencies, Ethiopia has not made sufficient
progress in implementing its action plan, and certain strategic AML/CFT deficiencies remain. Ethiopia 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 and procedures to identify and freeze terrorist assets; (3) ensuring a fully operational and
effectively functioning Financial Intelligence Unit; and (4) implementing effective, proportionate and dissuasive sanctions in order to deal with
natural or legal persons that do not comply with the national AML/CFT requirements. The FATF encourages Ethiopia 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. However, despite Indonesia’s high-level political commitment to work with the
FATF and APG to address its strategic AML/CFT deficiencies, Indonesia has not made sufficient progress in implementing its action plan, and
certain strategic AML/CFT deficiencies remain. Indonesia 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; and (3) amending and implementing laws or other instruments to fully implement the Terrorist Financing Convention. The FATF
encourages Indonesia to address its remaining deficiencies, particularly by passing adequate CFT legislation, and continue the process of
implementing its action plan.

Kenya

Kenya has taken significant steps towards improving its AML/CFT regime, including the enactment of the Prevention of Terrorism Act and the
Capital Market (Amendment) Bill and the passage by Parliament of the Proceeds of Crime and Anti-Money Laundering (Amendment) Act and the
Finance Bill. The FATF has not yet assessed these laws due to their very recent nature, and therefore the FATF could not determine the extent
to which they address any of the following issues: (1) adequately criminalising money laundering and terrorist financing; (2) ensuring a fully
operational and effectively functioning Financial Intelligence Unit; (3) establishing and implementing an adequate legal framework for the
confiscation of funds related to money laundering, and the identification and freezing of terrorist assets; (4) implementing effective,
proportionate and dissuasive sanctions in order to deal with natural or legal persons that do not comply with the national AML/CFT
requirements; (5) implementing an adequate and effective AML/CFT supervisory programme for all financial sectors; (6) enhancing financial
transparency; (7) further improving and broadening customer due diligence measures; and (8) establishing adequate record-keeping
requirements. Despite Kenya’s high-level political commitment to work with the FATF and ESAAMLG to address its strategic AML/CFT
deficiencies, Kenya has not made sufficient progress in implementing its action plan within the agreed timelines, and certain strategic AML/CFT
deficiencies may remain. The FATF encourages Kenya to address its remaining deficiencies and continue the process of implementing its action
plan.

Myanmar

Myanmar has taken steps towards improving its AML/CFT regime, including by removing its reservations to the extradition articles of the Vienna
Convention, the Palermo Convention and the Terrorist Financing Convention. 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 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.

Nigeria

Nigeria has taken steps towards improving its AML/CFT regime, including by the adoption by Parliament of both the Money Laundering
(Prohibition) Amendment Bill and the Terrorism (Prevention) Amendment Bill. The FATF has not yet assessed these laws due to their very
recent nature, and therefore the FATF could not determine the extent to which they address Nigeria’s two remaining issues regarding
criminalisation of money laundering and terrorist financing. The FATF encourages Nigeria to address its remaining deficiencies and continue the
process of implementing its action plan.

Pakistan

Pakistan has taken significant steps towards improving its AML/CFT regime, including introducing CFT amendments into Parliament. However,
despite Pakistan’s high-level political commitment to work with the FATF and APG to address its strategic AML/CFT deficiencies, Pakistan has
not yet made sufficient progress in fully implementing its action plan, and certain key CFT deficiencies remain. Specifically, Pakistan needs to
enact legislation to ensure that it meets the FATF standards regarding the terrorist financing offence and the ability to identify, freeze, and
confiscate terrorist assets. The FATF encourages Pakistan to address the remaining deficiencies and continue the process of implementing its
action plan.

São Tomé and Príncipe

Despite São Tomé and Príncipe’s high-level political commitment to work with the FATF and GIABA to address its strategic AML/CFT
deficiencies, São Tomé and Príncipe has not made sufficient progress in implementing its action plan, and certain strategic deficiencies remain.
São Tomé and Príncipe 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 a fully operational and effectively functioning Financial Intelligence Unit;
(3) ensuring that financial institutions and DNFBPs are subject to adequate AML/CFT regulation and supervision; and (4) implementing effective,
proportionate and dissuasive sanctions in order to deal with natural or legal persons that do not comply with the national AML/CFT
requirements. The FATF encourages São Tomé and Príncipe to address its remaining deficiencies and continue the process of implementing its
action plan.

Sri Lanka

Sri Lanka has taken significant steps towards improving its AML/CFT regime. However, despite Sri Lanka’s high-level political commitment to
work with the FATF and APG to address its strategic AML/CFT deficiencies, Sri Lanka has not made sufficient progress in implementing its
action plan. Sri Lanka should continue to work on addressing the remaining issue regarding adequate criminalisation of terrorist financing. The
FATF encourages Sri Lanka to address this deficiency and continue the process of implementing its action plan.

Syria

Previously, Syria had taken significant steps towards improving its AML/CFT regime. However, despite Syria’s high-level political commitment to
work with the FATF and MENAFATF to address its strategic AML/CFT deficiencies, Syria has not made sufficient progress in implementing its
action plan, and certain strategic AML/CFT deficiencies remain. Syria should continue to work on implementing its action plan to address these
deficiencies, including by: (1) providing sufficient legal basis for implementing the obligations under UNSCR 1373 and implementing adequate
procedures for identifying and freezing terrorist assets; and (2) ensuring that appropriate laws and procedures are in place to provide mutual
legal assistance. The FATF encourages Syria to demonstrate that its remaining deficiencies have been addressed to enable the FATF to
properly evaluate Syria’s progress.

Tanzania

Tanzania has taken steps towards improving its AML/CFT regime, including enactment of amendments to the Anti-Money Laundering Act and
the Prevention of Terrorism Act as well as the issuance of implementing regulations which expand on requirements related to customer due
diligence and recordkeeping and provide for an operational independent national Financial Intelligence Unit. However, despite Tanzania’s high-
level political commitment to work with the FATF and ESAAMLG to address its strategic AML/CFT deficiencies, Tanzania has not made sufficient
progress in implementing its action plan within the agreed timelines, and certain strategic AML/CFT deficiencies remain. Tanzania should
continue to work on implementing its action plan to address these deficiencies, including by: (1) clarifying the remaining issues regarding the
predicate offences for money laundering and criminalisation of terrorist financing; (2) establishing and implementing adequate procedures to
identify and freeze terrorist assets as well as implementing the UNSCRs 1267 and 1373 through law, regulations or other enforceable means.
The FATF encourages Tanzania to address its remaining deficiencies, including ratifying the Terrorist Financing Convention, and continue the
process of implementing its action plan.

Thailand

Thailand has taken steps towards improving its AML/CFT regime, including by issuing customer due diligence regulations. However, despite
Thailand’s high-level political commitment to work with the FATF and APG to address its strategic AML/CFT deficiencies, Thailand has not made
sufficient progress in implementing its action plan, and certain strategic AML/CFT deficiencies remain, although Thailand has faced external
difficulties from 2009 to 2011 which significantly impacted the legislative process for the necessary laws and regulations. Thailand should
continue to work on implementing its action plan to address the remaining deficiencies, including by: (1) adequately criminalising terrorist
financing; (2) establishing and implementing adequate procedures to identify and freeze terrorist assets; and (3) further strengthening AML/CFT
supervision. The FATF encourages Thailand to address its remaining deficiencies and continue the process of implementing its action plan,
specifically enacting its draft CFT legislation.

Turkey*

Despite Turkey’s high-level political commitment to work with the FATF to address its strategic CFT deficiencies, Turkey has not made sufficient
progress in implementing its action plan, and certain strategic CFT deficiencies remain. Turkey should work on addressing these deficiencies,
including by: (1) adequately criminalising terrorist financing; and (2) implementing an adequate legal framework for identifying and freezing
terrorist assets. Given Turkey’s continued lack of progress in these two areas, as a counter-measure, the FATF has decided to suspend Turkey’
s membership on 22 February 2013 unless the following conditions are met before that date: (1) Turkey adopts legislation to adequately remedy
deficiencies in its terrorist financing offence; and (2) Turkey establishes an adequate legal framework for identifying and freezing terrorist assets
consistent with the FATF Recommendations. FATF calls upon countries to take additional steps as necessary proportionate to the risks arising
from the deficiencies associated with Turkey.

Vietnam

Vietnam has taken steps towards improving its AML/CFT regime. However, despite Vietnam’s high-level political commitment to work with the
FATF and APG to address its strategic AML/CFT deficiencies, Vietnam has not made sufficient progress in implementing its action plan, and
certain strategic AML/CFT deficiencies remain. Vietnam should continue to work with the FATF and APG on implementing its action plan to
address these deficiencies, including by: (1) address the remaining issues regarding adequate criminalisation of terrorist financing; (2)
establishing and implementing adequate procedures to identify and freeze terrorist assets; (3) making legal persons subject to criminal liability
in line with FATF Standards or demonstrating that there is a constitutional prohibition that prevents this; (4) improving the overall supervisory
framework); (5) improving and broadening customer due diligence measures and reporting requirements; and (6) strengthening international co-
operation. The FATF encourages Vietnam to address its remaining deficiencies and continue the process of implementing its action plan.

Yemen

Despite Yemen’s high-level political commitment to work with the FATF and MENAFATF to address its strategic AML/CFT deficiencies, Yemen
has not made sufficient progress in implementing its action plan and certain strategic AML/CFT deficiencies remain. Yemen should continue to
work on implementing its action plan to address these deficiencies, including by: (1) adequately criminalizing money laundering and terrorist
financing; (2) establishing and implementing adequate procedures to identify and freeze terrorist assets; (3) developing the monitoring and
supervisory capacity of the financial sector supervisory authorities and the Financial Intelligence Unit (FIU) to ensure compliance by financial
institutions with their suspicious transaction reporting obligations, especially in relation to the financing of terrorism; and (4) ensuring a fully
operational and effectively functioning FIU. The FATF encourages Yemen to address its remaining deficiencies and continue the process of
implementing its action plan.

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Ghana

Pursuant to Ghana’s progress in largely addressing its action plan agreed upon with the FATF, Ghana is now identified in the FATF’s separate
but related public document, “Improving Global AML/CFT Compliance: On-going Process.”


Jurisdictions which have strategic AML/CFT deficiencies for which they have developed an action plan with the FATF

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
Albania
Algeria
Angola
Antigua and Barbuda
Argentina
Bangladesh
Brunei Darussalam
Cambodia
Ghana
Kyrgyzstan
Kuwait
Mongolia
Morocco
Namibia
Nepal
Philippines
Sudan
Tajikistan
Venezuela

Nicaragua
Zimbabwe


Trinidad and Tobago                    


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 then, Afghanistan has taken steps towards improving its AML/CFT regime, including by establishing high level AML/CFT coordination
mechanisms. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Afghanistan 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) 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

In June 2012, Albania made a high-level political commitment to work with the FATF and MONEYVAL to address its strategic AML/CFT
deficiencies. Since then, Albania has taken steps towards improving its AML/CFT regime, including by enacting legislation to implement
adequate customer due diligence provisions. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Albania
should continue to work on implementing its action plan to address these deficiencies, including by: (1) establishing and implementing an
adequate legal framework for identifying, tracing and freezing terrorist assets; and (2) enhancing the framework for international co-operation
related to terrorist financing. The FATF encourages Albania to address its remaining deficiencies and continue the process of implementing its
action plan.

Algeria

In October 2011, Algeria made a high-level political commitment to work with the FATF and MENAFATF to address its strategic AML/CFT
deficiencies. Since then, Algeria has taken steps towards improving its AML/CFT regime, including expanding the financial entities subject to
reporting requirements, providing for the legal autonomy of the Financial Intelligence Unit and expanding its powers to request information and
share information with other competent authorities. However, the FATF has concerns that strategic AML/CFT deficiencies remain and, therefore,
further engagement with Algeria is needed to clarify whether these deficiencies have been addressed. Algeria should continue to work on
implementing its action plan, including by: (1) adequately criminalising terrorist financing; (2) establishing and implementing an adequate legal
framework for identifying, tracing and freezing terrorist assets; (3) improving and broadening customer due diligence measures; and (4)
ensuring a fully operational and effectively functioning Financial Intelligence Unit. The FATF encourages Algeria to address its deficiencies and
continue the process of implementing its action plan.

Angola

In June 2010, Angola made a high-level political commitment to work with the FATF to address its strategic AML/CFT deficiencies. Since June
2012, Angola has taken steps towards improving its AML/CFT regime. However, the FATF has determined that certain strategic AML/CFT
deficiencies remain. Angola should continue to work on implementing its action plan to address these deficiencies, including by: (1) adequately
criminalising money laundering and terrorist financing; (2) ensuring a fully operational and effectively functioning Financial Intelligence Unit; and
(3) establishing and implementing an adequate legal framework to identify and freeze terrorist assets without delay. The FATF encourages
Angola to address its remaining deficiencies and continue the process of implementing its action plan.

Antigua and Barbuda

In February 2010, Antigua and Barbuda made a high-level political commitment to work with the FATF and CFATF to address its strategic
AML/CFT deficiencies. Since June 2012, Antigua and Barbuda has taken steps towards improving its AML/CFT regime, including by enacting
amendments to its Banking Act. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Antigua and Barbuda
should continue to work on implementing its action plan to address these deficiencies, including by continuing to improve the overall supervisory
framework. The FATF encourages Antigua and Barbuda to address its remaining deficiencies and continue the process of implementing its
action plan.

Argentina

In June 2011, Argentina made a high-level political commitment to work with the FATF to address its strategic AML/CFT deficiencies. Since June
2012, Argentina has taken substantial steps towards improving its AML/CFT regime, including by applying in practice Presidential Decree
918/2012 to freeze terrorist-related assets. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Argentina
should continue to work on implementing its action plan to address these deficiencies, including by: (1) addressing the remaining deficiencies
with regard to the criminalisation of money laundering, confiscation of funds related to money laundering, and freezing terrorist-related assets;
(2) continuing to enhance financial transparency; (3) addressing the remaining issues for the Financial Intelligence Unit and suspicious
transaction reporting requirements; (4) further enhancing the AML/CFT supervisory programme for all financial sectors; (5) further improving
and broadening customer due diligence measures; and (6) enhancing the appropriate channels for international co-operation and ensuring
effective implementation. The FATF encourages Argentina to address its remaining deficiencies and continue the process of implementing its
action plan.

Bangladesh

In October 2010, Bangladesh made a high-level political commitment to work with the FATF and APG to address its strategic AML/CFT
deficiencies. Since June 2012, Bangladesh has taken steps towards improving its AML/CFT regime. However, the FATF has determined that
certain strategic AML/CFT deficiencies remain. Bangladesh 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) ensuring a fully operational and effectively functioning Financial Intelligence Unit; (4) improving international co-
operation; and (5) issuing guidance to capital markets intermediaries to ensure their AML/CFT obligations are complied with. The FATF
encourages Bangladesh to address its remaining deficiencies and continue the process of implementing its action plan.

Brunei Darussalam

In June 2011, Brunei Darussalam made a high-level political commitment to work with the FATF and APG to address its strategic AML/CFT
deficiencies. Since June 2012, Brunei Darussalam has taken steps towards improving its AML/CFT regime, including by enacting appropriate
mutual legal assistance legislation. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Brunei Darussalam
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) ensuring a fully operational and effectively functioning Financial Intelligence Unit. The
FATF encourages Brunei Darussalam to address its remaining deficiencies and continue the process of implementing its action plan.

Cambodia

In June 2011, Cambodia made a high-level political commitment to work with the FATF and APG to address its strategic AML/CFT deficiencies.
The FATF has determined that certain strategic AML/CFT deficiencies remain. Cambodia 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 to identify and freeze terrorist assets; (3) establishing and implementing adequate procedures for the
confiscation of funds related to money laundering; (4) ensuring a fully operational and effectively functioning Financial Intelligence Unit; and (5)
establishing and implementing effective controls for cross-border cash transactions. The FATF encourages Cambodia to address its remaining
deficiencies and continue the process of implementing its action plan.

Ghana

Pursuant to Ghana’s progress in largely addressing its action plan agreed upon with the FATF, Ghana has been removed from the FATF’s
Public Statement and identified in this document. Since October 2010 when Ghana made a high-level political commitment to work with the FATF
and GIABA to address its strategic AML/CFT deficiencies, Ghana has taken important steps towards improving its AML/CFT regime, including by
enacting legislation to criminalize money laundering, establishing and implementing adequate measures for the confiscation of funds related to
money laundering, improving customer due diligence measures and enhancing the effectiveness of the Financial Intelligence Unit. 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.

Kyrgyzstan

In October 2011, Kyrgyzstan made a high-level political commitment to work with the FATF and EAG to address its strategic AML/CFT
deficiencies. Since June 2012, Kyrgyzstan has taken steps towards improving its AML/CFT regime, including by enacting AML amendments.
However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Kyrgyzstan should continue to work on implementing its
action plan to address these deficiencies, including by: (1) addressing the remaining issue regarding criminalisation of money laundering; (2)
adequately criminalising terrorist financing; (2) establishing and implementing an adequate legal framework for identifying, tracing and freezing
terrorist assets; (3) addressing remaining issues regarding the implementation of adequate measures for the confiscation of funds related to
money laundering; (4) establishing effective customer due diligence measures for all financial institutions; and (5) implementing an adequate
and effective AML/CFT supervisory programme for all financial sectors. The FATF encourages Kyrgyzstan to address its deficiencies and
continue the process of implementing its action plan, in particular swiftly enacting adequate CFT amendments.

Kuwait

In June 2012, Kuwait made a high-level political commitment to work with the FATF and MENAFATF to address its strategic AML/CFT
deficiencies. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Kuwait should continue to work on
implementing its action plan to address these deficiencies, including by: (1) adequately criminalising terrorist financing; (2) implementing the
Terrorist Financing Convention; (3) establishing and implementing adequate procedures to identify and freeze terrorist assets; (4) ensuring that
appropriate laws and procedures are in place to provide mutual legal assistance; (5) establishing effective customer due diligence measures;
(6) ensuring a fully operational and effectively functioning Financial Intelligence Unit (FIU), in particular addressing the operational autonomy of
the FIU; and (7) ensuring that financial institutions are aware of and comply with their obligations to file suspicious transaction reports in relation
to money laundering and terrorist financing. The FATF encourages Kuwait to address its remaining deficiencies and continue the process of
implementing its action plan.

Mongolia

In June 2011, Mongolia made a high-level political commitment to work with the FATF and APG to address its strategic AML/CFT deficiencies.
Since June 2012, Mongolia has taken steps towards improving its AML/CFT regime, including by establishing a dedicated AML unit within its
police department. However, the FATF has determined that strategic AML/CFT deficiencies remain. Mongolia 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 to identify and freeze terrorist assets; (3) establishing adequate procedures for the
confiscation of funds related to money laundering; (4) establishing suspicious transaction reporting requirements; and (5) demonstrating
effective regulation of money service providers. The FATF encourages Mongolia to address its remaining deficiencies and continue the process
of implementing its action plan.

Morocco

In February 2010, Morocco made a high-level political commitment to work with the FATF and MENAFATF to address its strategic AML/CFT
deficiencies. Since then, Morocco has demonstrated progress in improving its AML/CFT regime, including by adopting amendments to extend
the scope of the money laundering and terrorist financing offences, to broaden customer due diligence requirements and taking steps to
operationalise the Financial Intelligence Unit. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Morocco
should continue to work on implementing its action plan to address these deficiencies, including by enacting legislation to adequately criminalize
terrorist financing.

Namibia

In June 2011, Namibia made a high-level political commitment to work with the FATF and ESAAMLG to address its strategic AML/CFT
deficiencies. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Namibia 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) implementing an adequate AML/CFT supervisory programme with
sufficient powers; (4) ensuring a fully operational and effectively functioning Financial Intelligence Unit (FIU), in particular addressing the
operational autonomy of the FIU; and (5) implementing effective, proportionate and dissuasive sanctions in order to deal with non-compliance
with the national AML/CFT requirements. The FATF encourages Namibia to address its remaining deficiencies and continue the process of
implementing its action plan.

Nepal

In February 2010, Nepal made a high-level political commitment to work with the FATF and APG to address its strategic AML/CFT deficiencies.
Since June 2012, Nepal has taken steps to improve its AML/CFT system, including by ensuring that information held by the FIU is securely
protected. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Nepal 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 to identify and freeze terrorist assets; (3) implementing adequate procedures for the
confiscation of funds related to money laundering; (4) enacting and implementing appropriate mutual legal assistance legislation; (5) ensuring a
fully operational and effectively functioning Financial Intelligence Unit; and (6) establishing adequate suspicious transaction reporting obligations
for ML and FT. The FATF encourages Nepal to address its remaining deficiencies and continue the process of implementing its action plan.

Philippines

In October 2010, the Philippines made a high-level political commitment to work with the FATF and APG to address its strategic AML/CFT
deficiencies. Since June 2012, the Philippines has taken steps to improve its AML/CFT system, including by issuing the implementing rules and
regulations for the recently enacted CFT law. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. The
Philippines should continue to work on implementing its action plan to address these deficiencies, including by: (1) taking additional measures to
adequately criminalise money laundering; and (2) extending coverage of reporting entities to include designated non-financial businesses and
professions. The FATF encourages the Philippines to address its remaining deficiencies and continue the process of implementing its action
plan. In particular, the FATF strongly encourages the Philippines to enact the pending legislative amendment on AML.

Sudan

In February 2010, Sudan made a high-level political commitment to work with the FATF and MENAFATF to address its strategic AML/CFT
deficiencies. However, the FATF has determined that certain strategic AML/CFT deficiencies remain. Sudan should continue to work on
implementing its action plan to address these deficiencies, including by: (1) implementing adequate procedures for identifying and freezing
terrorist assets; (2) ensuring a fully operational and effectively functioning Financial Intelligence Unit; and (3) ensuring an effective supervisory
programme for AML/CFT compliance. The FATF encourages Sudan to address its remaining deficiencies and continue the process of
implementing its action plan.

Tajikistan

In June 2011, Tajikistan made a high-level political commitment to work with the FATF and EAG to address its strategic AML/CFT deficiencies.
Since June 2012, Tajikistan has taken steps towards improving its AML/CFT regime. However, the FATF has determined that certain strategic
AML/CFT deficiencies remain. Tajikistan should continue to work on implementing its action plan to address these deficiencies, including by: (1)
addressing remaining issues regarding criminalisation of money laundering and terrorist financing; (2) establishing and implementing adequate
procedures for the confiscation of funds related to money laundering and identifying and freezing terrorist assets; (3) addressing the remaining
issues relating to the Financial Intelligence Unit and improving suspicious transaction reporting requirements; and (4) improving and broadening
customer due diligence measures. The FATF encourages Tajikistan to address its remaining deficiencies and continue the process of
implementing its action plan.

Venezuela

In October 2010, Venezuela made a high-level political commitment to work with the FATF and CFATF to address its strategic AML/CFT
deficiencies. Since then, Venezuela has taken steps towards improving its AML/CFT regime, including by enacting AML/CFT legislation that
criminalises terrorist financing and establishes suspicious transaction reporting (STR) obligations for money laundering and financing of
terrorism, and issuing new resolutions aimed at establishing and implementing adequate procedures to identify and freeze 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.

Trinidad and Tobago

The FATF welcomes Trinidad and Tobago’s significant progress in improving its AML/CFT regime and notes that Trinidad and Tobago 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. Trinidad and Tobago is therefore no longer subject to FATF’s monitoring process under its on-going global
AML/CFT compliance process. Trinidad and Tobago will work with CFATF as it continues to address the full range of AML/CFT issues identified
in its Mutual Evaluation Report, particularly implementation of the new legislative and regulatory reform in order to more effectively combat illicit
finance in Trinidad and Tobago.


Jurisdictions not making sufficient progress

The FATF is not yet satisfied that the following jurisdictions have made sufficient progress on their action plan agreed upon with the FATF. The
most significant action plan items and/or the majority of the action plan items have not been addressed. If these jurisdictions do not take
sufficient action to implement significant components of their action plan by February 2013, then the FATF will identify these jurisdictions as
being out of compliance with their agreed action plans and will take the additional step of calling upon its members to consider the risks arising
from the deficiencies associated with the jurisdiction.

Nicaragua

Despite Nicaragua’s high-level political commitment to work with the FATF and CFATF to address its strategic AML/CFT deficiencies, the FATF is
not yet satisfied that Nicaragua has made sufficient progress in implementing its action plan, and certain strategic AML/CFT deficiencies remain.
Nicaragua should work with the FATF and CFATF on implementing its action plan to address these deficiencies, including by: (1) establishing
effective customer due diligence measures and record-keeping requirements, in particular entities not currently regulated by the supervisory
authority; (2) establishing adequate suspicious transaction reporting obligations for ML and FT; (3) implementing an adequate AML/CFT
supervisory programme for all financial sectors; (4) ensuring a fully operational and effectively functioning Financial Intelligence Unit; and (5)
establishing adequate procedures for identifying and freezing terrorist assets. The FATF encourages Nicaragua to address its remaining
deficiencies and continue the process of implementing its action plan.

Zimbabwe

Despite Zimbabwe’s high-level political commitment to work with the FATF and ESAAMLG to address its strategic AML/CFT deficiencies, the
FATF is not yet satisfied that Zimbabwe has made sufficient progress in implementing its action plan, and certain strategic AML/CFT deficiencies
remain. Zimbabwe should work with the FATF and ESAAMLG 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 to identify and
freeze terrorist assets; (3) ensuring a fully operational and effectively functioning Financial Intelligence Unit; (4) ensuring that financial
institutions are aware of and comply with their obligations to file suspicious transaction reports in relation to money laundering and the financing
of terrorism; (5) enacting and implementing appropriate mutual legal assistance legislation; and (6) ratifying the Terrorist Financing Convention.
The FATF encourages Zimbabwe to address its remaining deficiencies and continue the process of implementing its action plan.



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FATF List of Uncooperative Nations / AML/CTF Deficient  -  19 October 2012