The US Department of Treasury Financial Crimes Enforcement Network (FinCen) has withdrawn its Advisories in respect of the Bahamas, Cayman Islands, Liechtenstein and Panama. The Advisories were to inform banks and other financial institutions operating in the US of serious deficiencies in the counter money-laundering systems of the named jurisdictions. As a result of these deficiencies, enhanced scrutiny should be given to certain transactions or banking relationships involving the named jurisdictions, in the light of the suspicious transaction-reporting obligations of financial institutions operating in the US.
The move to withdraw the Advisories follows the de-listing of the four jurisdictions as non-cooperative countries by the Financial Action Task Force on money-laundering. FinCen said the Bahamas, Cayman Islands, Liechtenstein and Panama had enacted significant reforms to their counter money-laundering system and taken concrete steps to bring them into effect. Because of the enactment of new laws and the beginning of effective implementation, enhanced scrutiny with respect to transactions involving them is no longer necessary.
The four jurisdictions now have in place a counter money-laundering system that generally meets international standards, as reflected in the recent decision of the FATF to remove them from its list of countries that are non-cooperative in the fight against money-laundering.
But the withdrawal of the Advisories does not relieve institutions of their pre-existing and ongoing obligation to report suspicious activity as well as their obligation to comply with all other applicable provisions of law. And for Panama, with respect to transactions involving the Colon Free Zone, reference is made to Advisories 9 and 12 relating to the Black Market Peso Exchange.
FinCen Advisories remain in place for: the Cook Islands, Dominica, Israel, Lebanon, Marshall Islands, Nauru, Niue, Philippines, Russia, St Kitts & Nevis, St Vincent & the Grenadines.