The second question addresses whether legal persons, that is, corporations, partnerships, organizations, or any legal entity or arrangement, are liable for money laundering/terrorist financing activity and whether they are subject to criminal penalties, such as fines. Additionally, are they subject to civil or administrative penalties, such as civil money penalties, or suspension or loss of license?

CDD or KYC programs should apply not only to banks or financial institutions but also to DNFBPs. Covered institutions should be required to know, record, and report the identity of customers engaging in significant transactions. Entities such as securities and insurance brokers, money exchanges or remitters, financial management firms, gaming establishments, lawyers, real estate brokers, high-value goods dealers, and accountants, among others, should all be covered by such programs.


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Suspicious transaction reporting requirements should apply not only to banks or financial institutions but also to DNFBPs. Entities such as securities and insurance brokers, money exchanges or remitters, financial management firms, gaming establishments, lawyers, real estate brokers, high-value goods dealers, and accountants, among others, should all be covered by such programs.

If available, the report will include the numbers of money laundering prosecutions and convictions and the relevant time frames. The most recent information, preferably the activity in 2013, will be included.

This response will indicate if the country/jurisdiction has in place a mutual legal assistance treaty with the United States and/or other mechanisms, such as memoranda of understanding or other agreements, to facilitate the sharing with the United States of records and information related to financial crimes, money laundering, and terrorist financing.

Similarly, it will indicate if the country/jurisdiction has in place treaties, memoranda of understanding, or other agreements with other governments to share information related to financial crimes, money laundering, and terrorist financing.

Each year, Basel prepares an independent score and ranking that assesses the world's risk of money laundering and terrorist financing. This ranking is the Basel AML Index. Published by the Basel Institute of Governance in 2012, this document gives risk scores based on data from 15 publicly available sources, such as the Financial Action Task Force (FATF), the World Bank, and the World Economic Forum. FATF country's risk scores cover five areas:

Significant disparities in risk levels are evident across various aspects, including corruption and bribery, human trafficking, environmental crime, public and financial transparency, as well as the political and legal system within this region. Approximately one-third of the jurisdictions are identified as high-risk. Similar to the situation in Latin America, the profits derived from drug trafficking raise particular apprehension, with 40 percent of countries being identified by the US International Narcotics Control Strategy Report as significant money laundering jurisdictions in this context. The effectiveness of AML/CFT measures aimed at preventing the proliferation of weapons of mass destruction is generally subpar, as are the measures pertaining to prevention and transparency in beneficial ownership.


To improve supervision generally and enhance the effectiveness of regulatory implementation, several key actions can be undertaken. Strengthening regulatory frameworks is crucial by aligning them with international standards, such as those established by FATF, through regular updates and refinements to address emerging risks and stay ahead of evolving money laundering and terrorist financing techniques.

Governments should invest in building the capacity of regulatory and supervisory bodies responsible for overseeing anti-money laundering and counter-terrorism financing measures. Adequate resources, training programs, and expertise must be provided to ensure the effective implementation of supervisory functions.

By incorporating Sanction Scanner's robust features, including real-time screening against global sanctions lists, politically exposed persons (PEPs) databases, and adverse media sources, supervisory authorities can strengthen their capabilities in identifying and mitigating potential risks associated with money laundering and terrorist financing.

The 2003 INCSR assigned priorities to jurisdictions using a classification system consisting of three differential categories titled Jurisdictions of Primary Concern, Jurisdictions of Concern, and Other Jurisdictions Monitored. The "Jurisdictions of Primary Concern" are those jurisdictions that are identified pursuant to the INCSR reporting requirements as "major money laundering countries." A major money laundering country is defined by statute as one "whose financial institutions engage in currency transactions involving significant amounts of proceeds from international narcotics trafficking." However, the complex nature of money laundering transactions today makes it difficult in many cases to distinguish the proceeds of narcotics trafficking from the proceeds of other serious crime. Moreover, financial institutions engaging in transactions involving significant amounts of proceeds of other serious crime are vulnerable to narcotics-related money laundering. The category "Jurisdiction of Primary Concern" recognizes this relationship by including all countries and other jurisdictions whose financial institutions engage in transactions involving significant amounts of proceeds from all serious crime. Thus, the focus of analysis in considering whether a country or jurisdiction should be included in this category is on the significance of the amount of proceeds laundered, not of the anti-money laundering measures taken. This is a different approach taken than that of the FATF Non-Cooperative Countries and Territories (NCCT) exercise, which focuses on a jurisdiction's compliance with stated criteria regarding its legal and regulatory framework, international cooperation, and resource allocations. All other countries and jurisdictions evaluated in the INCSR are separated into the two remaining groups, "Jurisdictions of Concern" and "Other Jurisdictions Monitored," on the basis of a number of factors that can include: (1) whether the country's financial institutions engage in transactions involving significant amounts of proceeds from serious crime; (2) the extent to which the jurisdiction is or remains vulnerable to money laundering, notwithstanding its money laundering countermeasures, if any (an illustrative list of factors that may indicate vulnerability is provided below) ; (3) the nature and extent of the money laundering situation in each jurisdiction (for example, whether it involves drugs or other contraband); (4) the ways in which the United States regards the situation as having international ramifications; (5) the situation's impact on U.S. interests; (6) whether the jurisdiction has taken appropriate legislative actions to address specific problems; (7) whether there is a lack of licensing and oversight of offshore financial centers and businesses; (8) whether the jurisdiction's laws are being effectively implemented; and (9) where U.S. interests are involved, the degree of cooperation between the foreign government and U.S. government agencies. Additionally, given concerns about the increasing interrelationship between inadequate money laundering legislation and terrorist financing in 2003, terrorist financing was an additional factor considered in making a determination as to whether a country should be considered an "Other Jurisdiction Monitored " or a "Jurisdiction of Concern". A government (e.g., the United States or the United Kingdom) can have comprehensive anti-money laundering laws on its books and conduct aggressive anti-money laundering enforcement efforts but still be classified a "Primary Concern" jurisdiction. In some cases, this classification may simply or largely be a function of the size of the jurisdiction's economy. In such jurisdictions quick, continuous and effective anti-money laundering efforts by the government are critical. While the actual money laundering problem in jurisdictions classified "Concern" is not as acute, they too must undertake efforts to develop or enhance their anti-money laundering regimes. Finally, while jurisdictions in the "Other" category do not pose an immediate concern, it will nevertheless be important to monitor their money laundering situations because, under the right circumstances, virtually any jurisdiction of any size can develop into a significant money laundering center. Vulnerability FactorsThe current ability of money launderers to penetrate virtually any financial system makes every jurisdiction a potential money laundering center. There is no precise measure of vulnerability for any financial system, and not every vulnerable financial system will, in fact, be host to large volumes of laundered proceeds, but a checklist of what drug money managers reportedly look for provides a basic guide. The checklist includes: Failure to criminalize money laundering for all serious crimes or limiting the offense to narrow predicates.

Jurisdiction moving from the Primary Concern Column to the Concern Column: Dominica. Jurisdictions moving from the Concern Column to the Other Column: Marshall Islands, Niue. Jurisdictions moving from the Concern Column to the Primary Concern Column: Bosnia and Herzegovina, and Latvia. Jurisdictions moving from the Other Column to the Concern Column: Afghanistan, Bangladesh, Belarus, Cote d'Ivoire, Iran, Jordan, Kenya, Kuwait, Morocco, Qatar, Saudi Arabia, Sierra Leone, Syria, and Tanzania. The following countries were added to the Money Laundering & Financial Crimes report this year and are included in the "Other" Column: Burundi, Djibouti, East Timor, Guinea-Bissau, Rwanda, and San Marino. In the Country/Jurisdiction Table on the following page, "major money laundering countries" that are included in the "jurisdictions of primary concern" list are identified for purposes of statutory INCSR reporting requirements. Identification as a "major money laundering country" is based on whether the country or jurisdiction's financial institutions engage in transactions involving significant amounts of proceeds from serious crime. It is not based on an assessment of the country or jurisdiction's legal framework to combat money laundering; its role in the terrorist financing problem; or the degree of its cooperation in the international fight against money laundering, including terrorist financing. These factors, however, are included among the vulnerability factors when deciding whether to place a country in the "concern" or "other" column. Country/Jurisdiction Table Countries/Jurisdictions

of Primary Concern Countries/Jurisdictions

of Concern Countries/Jurisdictions

Monitored Antigua and BarbudaSingaporeAfghanistanPortugalAlgeriaMalawiAustraliaSpainAlbaniaQatarAndorraMaldivesAustriaSwitzerlandArgentinaRomaniaAngolaMaliBahamasTaiwanArubaSamoaAnguillaMaltaBosnia and HerzegovinaThailandBahrainSaudi ArabiaArmeniaMarshall IslandsBrazilTurkeyBangladeshSerbia and MontenegroAzerbaijanMauritiusBurmaUkraineBarbadosSeychellesBeninMicronesia FSCanadaUnited Arab EmiratesBelarusSierra LeoneBermudaMoldovaCayman IslandsUnited KingdomBelgiumSlovakiaBotswanaMongoliaChina, People RepUSABelizeSouth AfricaBruneiMontserratColombiaUruguayBoliviaSt. Kitts & NevisBurkina FasoMozambiqueCosta RicaVenezuelaBritish Virgin IslandsSt. LuciaBurundiNamibiaCyprusBulgariaSt. VincentCameroonNepalDominican RepublicCambodiaSyriaChadNew ZealandFranceChileTanzaniaCongo, Dem Rep ofNigerGermanyCook IslandsTurks and CaicosCongo, Rep ofNiueGreeceCote d'IvoireVanuatuCroatiaNorwayGuernseyCzech RepVietnamCubaOmanHaitiDominicaYemenDenmarkPapua New GuineaHong KongEcuadorDjiboutiRwandaHungaryEgyptEast TimorSan MarinoIndiaEl SalvadorEritreaSao Tome & PrincipeIndonesiaGibraltarEstoniaSenegalIsle of ManGrenadaEthiopiaSloveniaIsraelGuatemalaFijiSolomon IslandsItalyHondurasFinlandSri LankaJapanIranGabonSurinameJerseyIrelandGambiaSwazilandLatviaJamaicaGeorgiaSwedenLebanonJordanGhanaTajikistanLiechtensteinKenyaGuineaTogoLuxembourgKorea, NorthGuinea-BissauTongaMacauKorea, SouthGuyanaTrinidad and TobagoMexicoKuwaitIcelandTunisiaNauruMalaysiaKazakhstanTurkmenistanNetherlandsMonacoKyrgyzstanUgandaNigeriaMoroccoLaosUzbekistanPakistanNetherlands AntillesLesothoZambiaPanama NicaraguaLiberiaZimbabweParaguayPalauLithuaniaPhilippinesPeruMacedoniaRussiaPolandMadagascar 2351a5e196

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