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FATF definition Strategic deficiencies


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The FATF/GAFI is using the following definition for a jurisdiction with strategic deficiencies:

Jurisdictions under increased monitoring are actively working with the FATF to address strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing. When the FATF places a jurisdiction under increased monitoring, it means the country has committed to resolve swiftly the identified strategic deficiencies within agreed timeframes and is subject to increased monitoring. This list is often externally referred to as the “grey list”.

Impact on due diligence

The FATF does not call for the application of enhanced due diligence measures to be applied to these jurisdictions, but encourages its members and all jurisdictions to consider the information presented below in their risk analysis.

Comment / observation

Grey list – the FATF is being political here. Clearly regulators do expect market participants to take additional steps for countries on this list.

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