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Aki Corsoni-Husain
Aki Corsoni-Husain
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George Apostolou
George Apostolou
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Chiara Deceglie
Chiara Deceglie
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Massimiliano della Zonca
Massimiliano della Zonca
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Philip Graham
Philip Graham
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Ayana Hull
Ayana Hull
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Katerina Katsiami
Katerina Katsiami
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Petros Kiteos
Petros Kiteos
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Andrew Knight
Andrew Knight
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Joshua Mangeot
Joshua Mangeot
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Mirza Manraj
Mirza Manraj
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Elina Mantrali
Mirza Manraj
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Vanessa Molloy
Vanessa Molloy
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Andrea Moundi Savvides
Andrea Moundi Savvides
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Marina Stavrou
Marina Stavrou
  • Marina Stavrou

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Matt Taber
Matt Taber
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Carolynn Vivian
Carolynn Vivian
  • Carolynn Vivian

  • Senior Associate
  • Cayman Islands

BVI regulator comments on FATF statements regarding high (and higher) risk countries: compliance officers take note

On 3 March 2020, the BVI Financial Services Commission (BVI FSC) posted commentary on its website regarding two statements made by the Financial Action Task Force (FATF) on 21 February 2020 on anti-money laundering and terrorist financing considerations regarding:

  • countries subject to its ‘Call for Action’ programme, currently the highest risk category
  • countries subject to its ‘Increased Monitoring’ programme

North Korea and Iran: high risk jurisdictions subject to the Call for Action

FATF members are called to advise their financial institutions to give special attention to business relationships and transactions with businesses from:

  • the DPR Korea/North Korea (DPRK) for its government’s failure to address “significant” deficiencies in the local AML/CFT regime
  • the Islamic Republic of Iran’s for its failure to address its strategic AML/CFT deficiencies

In light of the above the BVI FSC in its commentary reminds BVI based entities conducting business, and who are required to comply with the AML/CFT regime, that they should note the FATF’s concerns to the extent that they are providing services to customers in the DPRK or Iran. In line with FATF requirements enhanced customer due diligence must be followed and, to the extent necessary, staff of BVI entities should liaise with their compliance personnel who can in turn liaise with the competent authority, if necessary.

Jurisdictions under Increased Monitoring

The following countries are subject to increased examination, also known as, grey list jurisdictions. These jurisdictions have given undertakings to work within the various FATF timeframes to address any strategic deficiencies where they may exist. Nevertheless, strategic deficiencies have been found to exist and are of relevance for BVI institutions in their business dealing. 

The countries subject to Increased Monitoring are:

Albania

Ghana

Myanmar

Uganda

The Bahamas

Iceland

Nicaragua

Yemen

Barbados

Jamaica

Pakistan

Zimbabwe

Bostwana

Mauritius

Panama

 

Cambodia

Mongolia

Syria

 

It will be noted that a number of the above are jurisdictions highly relevant to the BVI both in terms of regional proximity and in terms of business flow.

The FATF is the global body that promotes measures for combating money laundering, terrorist financing, proliferation financing (together the AML/CFT) and other factors that may pose as a threat or hindrance to the international financial systems the world over.

The FATF statements can be found here.

The BVI FSC commentary can be found here.