FINTRAC Advisory Concerning Financial Transactions Related to High-Risk Countries Identified by the FATF

On November 18, 2024, the Financial Transactions and Reports Analysis Centre (FINTRAC) issued an updated advisory (the “Advisory”) concerning financial transactions related to countries identified by the Financial Action Task Force (FATF) as high-risk jurisdictions and under increased monitoring.

Background

The Advisory follows two statements recently issued by the FATF:

• a statement on high risk jurisdictions subject to a call for action, which identifies jurisdictions for which the FATF has called on countries to apply countermeasures or enhanced due diligence; and
• a statement on jurisdictions under increased monitoring, which identifies jurisdictions that have developed an action plan with the FATF to address deficiencies in their anti-money laundering and counter-terrorist financing strategies.

Takeaways from the Advisory

The Advisory focuses on key aspects of various FATF statements and notes FINTRAC expectations. The Advisory also references earlier statements issued by the FATF in respect of various matters concerning high-risk jurisdictions. (See our November 2022, March 2023, July 2023, November 2023, May 2024, and August 2024 updates relating to earlier advisories.)

The Advisory specifically notes the following:

• The Democratic People’s Republic of Korea and Iran remain jurisdictions for which the FATF has called on its members to apply countermeasures.
• Myanmar remains a jurisdiction for which the FATF has called on its members to apply enhanced due diligence measures proportionate to the risks arising from this jurisdiction.
• Algeria, Angola, Bulgaria, Burkina Faso, Cameroon, Côte d’Ivoire, Croatia, Democratic Republic of the Congo, Haiti, Kenya, Lebanon, Mali, Monaco, Mozambique, Namibia, Nigeria, Philippines, South Africa, South Sudan, Syria, Tanzania, Venezuela, Vietnam, and Yemen are on the ‘grey list’ and subject to the FATF’s increased monitoring process.
• Senegal is no longer subject to increased monitoring.

The Advisory also reminds reporting entities that, as of August 19, 2024, they must report to FINTRAC transactions suspected to be related to sanctions evasion, including with respect to financial transactions associated with Russia. Reporting entities also have other legal obligations under Canada’s sanctions laws and associated regulations with respect to the monitoring and reporting of relevant property ownership, export and import of goods, and other activity in connection with sanctioned individuals and entities. See our June 2024 update relating to sanctions reporting requirements.

For further information concerning the matters referenced in the updated Advisory and what they might mean from a compliance perspective, please contact any member of our Financial Services Regulatory Group.

The author would like to thank Cathy Costa-Faria, Associate, for her assistance in writing this Update.