As a result of Covid-19 and the ability of countries to actively participate in mutual evaluation and related follow-up processes in April 2020 FATF temporarily postponed all remaining mutual evaluation and follow-up deadlines.
At its June 2020 virtual plenary, FATF made the initial determination that both Iceland and Mongolia had substantially completed their action plans and warrant on-site assessments to verify that the implementation of their respective AML/CFT reforms has begun and is being sustained, and that the necessary political commitment remains in place to sustain implementation in the future. FATF will continue to monitor the COVID-19 situation and conduct these on-site visits at the earliest possible date. Therefore, FATF’s list of jurisdictions that have strategic AML/CFT deficiencies remains the same as in February 2020 with the caveat that both Iceland and Mongolia are in a strong position to be removed, subject to on-site assessment.
Thus, List B, as issued by the Cabinet Office, remains unchanged however a footnote has been inserted against the entries for Iceland and Mongolia to explain the circumstances.
If your business has customers in or from either of these two countries then strict application of paragraph 15(7) of the AML/CFT Code would require you to consider if that customer poses a higher risk of ML/FT. The addition of this footnote does not remove that obligation but does provide more persuasive evidence subject to any other higher risk indicators that may be present when considering the customer relationship as a whole that the risk may not pose a higher risk of ML/TF.