Money Laundering and Terrorist Financing Advisory Issued


Last week Bermuda Attorney General and Minister of Legal Affairs Hon. Trevor Moniz, JP, MP issued an advisory about the risks in a number of jurisdictions stemming from inadequate systems and controls to combat money laundering and terrorist financing.  Details about these risks were provided by the Financial Action Task Force (FATF) and the Caribbean Financial Action Task Force (CFATF), in statements released in June 2016.

Below is a brief list of jurisdictions that have raised concerns or been recognized for improvements to previously identified deficiencies.


Jurisdictions which have raised concerns with the FATF:

Democratic People’s Republic of Korea (DPRK) – The FATF raises concerns over the continued failure to adequately address “ongoing and substantial deficiencies in its anti-money laundering and combatting the financing of terrorism (AML/CFT) regime.”

Iran – The FATF welcomed Iran’s adoption of and commitment to an Action Plan to address its strategic AML/ATF deficiencies and its decision to seek technical assistance in the implementation of the Action Plan. However, until Iran “implements the measures required to address the deficiencies identified in the Action Plan,” the FATF will remain concerned.

Afghanistan, Bosnia, Herzegovina, Guyana, Iraq, Lao PDR, Syria, Uganda, Vanuatu and Yemen – The FATF has called for expeditious implementation of these countries’ agreed action plans.

Jurisdictions which have raised concerns with the CFATF:

Haiti – According to the CFATF, Haiti has “failed to make sufficient progress in addressing its significant strategic AML/ATF deficiencies” including certain legislative reforms.

Jurisdictions acknowledged for their progress:

  • Myanamar
  • Papua New Guinea
  • Suriname

It is important that the annexed statements are read in their entirety. All financial institutions and other relevant persons, in the implementation of their systems and controls to combat financial crime, should give consideration to the FATF and CFATF assessments and take appropriate actions in light of the associated risks.

The Proceeds of Crime (Anti-Money Laundering and Anti-Terrorist Financing) Regulations in 2008 require AML/ATF regulated financial institutions and other relevant persons to have policies, procedures or systems in place to prevent money laundering or terrorist financing. Under the regulations, relevant persons are al so required, under certain specified situations, to apply enhanced customer due diligence measures and/or ongoing monitoring on a risk-sensitive basis.

A strong Anti-Money Laundering and Anti-Terrorist Financing (“AML/ATF”) Programme, with an experienced Money Laundering Reporting Officer are vital in protecting the reputation of any financial services organisation.  Regulators will continue to closely scrutinise organisations and how they define, implement and maintain their AML procedures. Additionally, a strong AML will protect you and your firm from fraud.  Oyster Consulting (Bermuda) has the experience and expertise necessary to assess your firm’s AML/ATF Programme and help you implement practical solutions to improve your control environment.

Oyster Consultant Henry Komansky will be hosting a series of Lunch and Learn sessions on the topic of AML/ATF regulations. For more information on these, please contact Henry Komansky at

To learn more about how Oyster Consulting can assist your firm, complete our contact form and one of our associates will be happy to help, or call us at 441.541.5036