Privacy Policy

Privacy Policy

Use of Your Personal Data

We collect Personal Data about you in an attempt to provide you with the best experience possible, protect you from risks related to improper use and fraud, and help us maintain and improve our Services. We may use your Personal Data to:

  • Facilitate the creation of and secure your account;
  • Identify you as a user in our system;
  • Provide you with our Services, including but not limited to assisting you in viewing, using, buying and selling non-fungible tokens (“NFTs”) with our tools, as well as connecting directly with others to buy, sell, or transfer NFTs on public blockchains at your discretion;
  • Improve the administration of our Service and the quality of your experience when you interact with it, for example, by studying how you and other users find and engage with it;
  • Provide customer support and respond to your requests and inquiries;
  • Investigate and address conduct that may violate our Terms of Service;
  • Detect, prevent, and address fraud, violations of our terms or policies, and/or other harmful or unlawful activity;
  • Display the NFTs currently or previously accessible in your wallet, and NFTs on which you have interacted;
  • Send you a welcome email to verify ownership of the email address provided when your account was created;
  • Send you administrative notifications, such as security, support, and maintenance advisories;
  • Send you notifications related to actions on the Services;
  • Send you newsletters, promotional materials, and other notices related to our Services or third parties’ goods and services;
  • React to your requests for information on job openings or other requests;
  • Comply with applicable laws, cooperate with law enforcement or other authorities in the investigation of suspected legal Violations, and/or pursue or defend legal threats and/or claims;

Personal Data We Collect

“Personal Data,” as used herein, refers to information that directly or indirectly identifies or is reasonably capable of identifying an individual, as well as information that can be linked to an identified or reasonably identifiable individual.

1. Personal Data we collect from you

We may collect the following categories of Personal Data directly from you:

  • Identification Information such as name, email, phone number, postal address;
  • Commercial Activity such as trading activity, order activity, deposits, withdrawals, account balances;
  • Correspondence such as information you provide to us in correspondence, including account opening and customer support; and
  • Sensory Information such as images that you upload to your Profile;

2. Personal Data we collect automatically

We may collect the following categories of Personal Data automatically through your use of our Services:

  • Online Identifiers such as IP address, domain name;
  • Device Information such as hardware, operating system, browser;
  • Usage Data such as system activity, internal and external information related to CorpAgent pages that you visit, clickstream information; and Geolocation Data.

Our automatic collection of Personal Data may involve the use of Cookies, described in greater detail below.

3. Personal Data we collect from third parties

Third parties, such as service providers and affiliates, may provide us with the following categories of Personal Data about you, which we may collect and/or verify:

  • Identification Information such as name, email, phone number, postal address
  • Public blockchain data isn’t completely anonymous. Because Personal Data published on a blockchain (such as your digital asset address and IP address) can be correlated with Personal Data that we and others may have, we and others who can match your public digital asset address to other Personal Data about you may be able to identify you from a blockchain transaction.
  • Furthermore, it may be possible to detect other Personal Data about you by using data analysis tools on a certain blockchain);
  • Financial Information such as bank account information, routing number, credit card number, debit card number; and
  • Additional Information at our discretion to comply with legal obligations.

4. Public Information Observed from Blockchains

We collect data from publicly visible and/or accessible blockchain activity. This could include blockchain addresses and information on NFT purchases, sales, or transfers, which could subsequently be linked to other information you’ve provided us.

5. Accuracy and retention of Personal Data

NewWe take reasonable and practicable steps to ensure that your Personal Data held by us is (i) accurate with regard to the purposes for which it is to be used, and (ii) not kept longer than is necessary for the fulfillment of the purpose for which it is to be used.

Privacy policy

CorpAgent Global (“CorpAgent,” “we” or “us”) provides you with a platform (“Platform”) that allows your access to and use of the CorpAgent website(s), our mobile app (the “App”), and any other software, tools, features, or functionalities (collectively, the “CorpAgent Network”) provided on or in connection with our features services (collectively, the “Services”).

We are committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect, why we collect it, and how we use and disclose it.

We care about your privacy, so please take the time to learn about and understand our policies and practices. Please be aware that we reserve the right to amend any of our policies and practices at any time, but the most recent version of this Privacy Policy may always be found on this page. We recommend that you review the Privacy Policy on a regular basis to ensure that you are familiar with the most updated version.

One IBC® safeguard

What is One IBC® Safeguard

One IBC® Safeguard is designed to allow us to better protect you, support you and your accounts from fraud and financial crime. To do this we need to ensure that all the information we hold for you or your business is correct, complete and up-to-date. Changes in regulations may also mean that we require some additional information which we have not previously asked you to provide.

  • Check and review all our customer accounts to check we have all the details we need.
  • Be in touch to confirm, update or request new information.

Personal Customers

If you’re a personal customer we’re likely to need 2 types of documents from you: to confirm your identity, and to confirm your address. Occasionally we may need more information than this.

Business Customers

If you’re a business customer the documents we need will depend on the size and nature of your business. However we are likely to need to confirm your legal entity structure, your beneficial owners and countries you do business with.

What we will do with your data?

The sole purpose of gathering this information is so that our systems and processes can protect both our customers and the One IBC® against financial crime. We take our obligation to protect your data very seriously, so all the information you provide will be subject the One IBC®’s high data and security standards. The intent is only to use this information for your protection and will NOT be used by any third parties for marketing purposes.

What is financial crime?

Fraud and financial crimes are forms of theft. They tend to involve money or property that are gained illegally, and used in a deceptive or illegal manner to gain a benefit from the proceeds. In today’s complex economy, financial crimes can take many forms including money laundering, sanctions breaches, fraud, tax evasion, terrorist financing, bribery and corruption.

What has financial crime got to do with me?

Financial crime can affect anyone and everyone. Your support will go a long way to help us do business safer.

What are Sanctions?

Sanctions are a policy tool which national governments and organisations such as the United Nations and European Union use to constrain and deter perceived threats to their security, or to conform international conduct to recognised international standards. Sanctions help to stop crimes like terrorism, drug trafficking and arms dealing by imposing restrictions on the business that banks can do with specific people, corporations or countries and the names of these are clearly listed on things like the Office of Foreign Assets (OFAC) sanctions list.

Why is financial crime an increasing concern?

At One IBC®, addressing financial crime globally has long been one of our main priorities.

However criminal activity has become increasingly sophisticated in recent years, and fraudsters, money launderers and others have attempted to target global networks.

Improving the way we share and manage customer information will help us fight against the risk of financial crime. After all, it’s our duty to ensure that you can do business with us safely, securely, and confidently.

What has financial crime got to do with you or your business?

As the world becomes more and more connected and information moves around at a greater pace, there are unfortunately greater opportunities for criminals to misuse the financial system.

A key defence against money laundering is to prevent accounts being opened in false identities. We also sometimes need to verify where funds are from as part of our ongoing efforts to track our customers’ legitimate funds and to protect them from financial crime. Criminals will try to appear to be law abiding citizens or businesses and therefore we need to request documentary evidence from all of our customers in order to fully protect them and their accounts.

Why are you asking for all this information? Don’t you already have it?

As well as acting to safeguard our customers, One IBC® has a commitment to meet regulatory and legal requirements by ensuring that the information we hold is up-to-date, complete and accurate. You might have already provided some of this information prior to this request, but to stay one step ahead of fraud and financial crime, we need to ensure we have your most up-to-date information.

What information do I need to provide?

The request you receive from us will detail all the information required, in most cases this will include a certified copy or original document verifying your residential address. For some of our customers we may also require a certified copy of your identification documentation (e.g. a valid passport). We’ll advise exactly what you’ll need to provide when we contact you. In certain cases we can only accept original documents which must be sent to us by post.

Why do you need information about my Source of Funds and Source of Wealth?

Regulatory and legal obligations require us to understand where funds are coming from and going to. This also helps us to protect you from fraud and financial crime.

What will happen if I don’t provide this information?

We are required by our regulators to have this information. If we don’t receive your up-to-date information we may no longer be able to provide you with our services. If you are having trouble gathering the information, need more time or have any further questions, please let us know and we will do our best to help.

Documents and Certification

Who can certify my documents?

The following people can certify photocopies of your documents, on sight of the original document:

  • Bank Manager of a licensed, regulated bank
  • Embassy Consulate or High Commission Official of the country of issue of the documentation
  • Lawyer or Notary Public*
  • A Member of the Judiciary
  • Actuary* of the country of issue of the documentation
  • Accountant or Tax Adviser*

*Who is a member of a recognised professional body

If you provide original utility bills to confirm your address, these do not need to be certified. We regret that we will not be able to return these documents to you.

How do I certify my documents?

Your documents must be certified within the last three months and be in English. We can only accept certified copies that have been translated into English, providing both the foreign and English copies are certified as required.

How can I send my documents to you?

Once your documents are certified, please send them with your completed Personal Information Form to the following address: Unit 1411, 14/Floor, Cosco Tower, 183 Queen’s Road Central, Sheung Wan, Hong Kong and/or scan it then send over email to vetting@oneibc.com.

Jurisdictions under Increased Monitoring – 21 October 2022

Jurisdictions under Increased Monitoring – 21 October 2022

Paris, 21 October 2022 – Jurisdictions under increased monitoring are actively working with the FATF to address strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing. When the FATF places a jurisdiction under increased monitoring, it means the country has committed to resolve swiftly the identified strategic deficiencies within agreed timeframes and is subject to increased monitoring. This list is often externally referred to as the “grey list”.

The FATF and FATF-style regional bodies (FSRBs) continue to work with the jurisdictions below as they report on the progress achieved in addressing their strategic deficiencies. The FATF calls on these jurisdictions to complete their action plans expeditiously and within the agreed timeframes. The FATF welcomes their commitment and will closely monitor their progress. The FATF does not call for the application of enhanced due diligence measures to be applied to these jurisdictions. The FATF Standards do not envisage de-risking, or cutting-off entire classes of customers, but call for the application of a risk-based approach. Therefore, the FATF encourages its members and all jurisdictions to take into account the information presented below in their risk analysis.

The FATF identifies additional jurisdictions, on an on-going basis, that have strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing. A number of jurisdictions have not yet been reviewed by the FATF or their FSRBs, but will be in due course.

Since the start of the COVID-19 pandemic, the FATF has provided some flexibility to jurisdictions not facing immediate deadlines to report progress on a voluntary basis. The following countries had their progress reviewed by the FATF since June 2022: Albania, Barbados, Burkina Faso, Cambodia, Cayman Islands, Haiti, Jamaica, Jordan, Mali, Morocco, Myanmar, Nicaragua, Pakistan, Panama, Philippines, Senegal, South Sudan, Türkiye, UAE, and Uganda. For these countries, updated statements are provided below. Gibraltar chose to defer reporting; thus, the statement issued in June 2022 for that jurisdiction is included below, but it may not necessarily reflect the most recent status of the jurisdiction’s AML/CFT regime. Following review, the FATF now also identifies the Democratic Republic of the Congo, Mozambique, and Tanzania.

The FATF welcomes the progress made by these countries in combating money laundering and terrorist financing, despite the challenges posed by COVID-19.

ALBANIA

  • Since February 2020, when Albania made a high-level political commitment to work with the FATF and MONEYVAL to strengthen the effectiveness of its AML/CFT regime, Albania has taken steps towards improving its AML/CFT regime, including by enacting an adequate legal framework for violations of company and NPO registration obligations and implementing proportionate and dissuasive sanctions against entities that failed to declare their beneficial owners in the registry by the deadline. Albania should continue to work on implementing its action plan to address its strategic deficiencies, including by increasing the number of money laundering indictments that it brings to court for prosecution.
  • The FATF expresses concern that Albania failed to complete its action plan, which fully expired in February 2022. The FATF strongly urges Albania to swiftly demonstrate significant progress in completing its action plan by February 2023 or the FATF will consider next steps if there is insufficient progress.
  • Additionally, the FATF expresses concern that Albania’s plans for a possible Voluntary Tax Compliance (VTC) programme do not comply with the FATF’s principles for managing the AML/CFT implications of VTCs or FATF’s best practices for such programmes. Albania should revise its draft VTC law and work with MONEYVAL to ensure that any VTC law passed or implemented has adequate safeguards to prevent the potential for abuse of the programme for money laundering or terrorist financing purposes.

BARBADOS

  • Since February 2020, when Barbados made a high-level political commitment to work with the FATF and CFATF to strengthen the effectiveness of its AML/CFT regime, Barbados has taken steps towards improving its AML/CFT regime, including by, demonstrating the ability to enforce breaches of BO requirements, strengthening the relationship between the FIU and LEAs, improving the ML database, and demonstrating progress in the investigation, seizure and forfeiture of cash and assets. Barbados should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) taking appropriate measures to prevent legal persons and arrangements from being misused for criminal purposes, and ensuring that accurate and up-to-date basic and beneficial ownership information is available on a timely basis; (2) demonstrating that ML investigations and prosecutions are in line with the country’s risk profile; (3) further pursuing confiscation in ML cases, including by repatriating or sharing confiscated assets with other countries.  
  • The FATF urges Barbados to swiftly complete its action plan as all deadlines have now expired and to address the above-mentioned strategic deficiencies by February 2023.

BURKINA FASO

  • Since February 2021, when Burkina Faso made a high-level political commitment to work with the FATF and GIABA to strengthen the effectiveness of its AML/CFT regime, Burkina Faso has taken steps towards improving its AML/CFT regime, including by strengthening its efforts to pursue confiscation as a policy objective. Burkina Faso should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) updating its understanding of ML/TF risks, including through the revision of the national risk assessment in line with the sectoral priorities identified in its national strategy; (2) seeking mutual legal assistance (MLA) and other forms of international cooperation in line with its risk profile; (3) strengthening of resource capacities of all AML/CFT supervisory authorities and implementing risk based supervision of FIs and DNFBPs; (4) maintaining comprehensive and updated basic and beneficial ownership information and strengthening the system of sanctions for violations of transparency obligations; (5) increasing the diversity of STR reporting; (6) enhancing the resources of the FIU to provide additional capacity building and training to FIs, DNFBPs and the investigative and judicial authorities; (7) conduct training for LEAs, prosecutors and other relevant authorities; (8) enhancing capacity and support for LEAs and prosecutorial authorities involved in combatting TF, in line with the TF National Strategy; and (9) implementing an effective targeted financial sanctions regime related to TF and PF as well as risk-based monitoring and supervision of NPOs.

CAMBODIA

  • In February 2019, Cambodia made a high-level political commitment to work with the FATF and APG to strengthen the effectiveness of its AML/CFT regime. At its October 2022 Plenary, the FATF made the initial determination that Cambodia has substantially completed its action plan and warrants an on-site visit to verify that the implementation of Cambodia’s AML/CFT reforms has begun and is being sustained, and that the necessary political commitment remains in place to sustain implementation and improvement in the future. Cambodia has made a number of key reforms, including to improve: (1) MLA law and providing training on MLA to prosecutors and judges; (2) risk-based supervision for FIs and DNFBPs; (3) the legal framework on preventive measures and conducting outreach to the casino, real-estate and MVTS sectors; (4) the quality and quantity of FIU disseminations, demonstrating an increase in ML investigations in line with risk; (5) its effectiveness in asset confiscation; and (6) establishing a legal framework for implementing UN sanctions related to targeted financial sanctions for PF and providing training to strengthen the skills of competent authorities to implement TFS for PF. The FATF will continue to monitor the COVID-19 situation and conduct an on-site visit at the earliest possible date.

THE CAYMAN ISLANDS

  • Since February 2021, when the Cayman Islands made a high-level political commitment to work with the FATF and CFATF to strengthen the effectiveness of its AML/CFT regime, the Cayman Islands has taken steps towards improving its AML/CFT regime, including by imposing adequate and effective sanctions in cases where relevant parties (including legal persons) do not file accurate, adequate and up-to-date beneficial ownership information in line with those requirements. The Cayman Islands should continue to work on implementing its action plan to address its strategic deficiencies, including by demonstrating that they are prosecuting all types of money laundering cases in line with the jurisdiction’s risk profile and that such prosecutions are resulting in the application of dissuasive, effective, and proportionate sanctions.
  • The FATF urges the Cayman Islands to swiftly complete its action plan as all deadlines have now expired and to address the above-mentioned strategic deficiency by February 2023.

THE DEMOCRATIC REPUBLIC OF THE CONGO

  • In October 2022, the DRC made a high-level political commitment to work with the FATF and GABAC to strengthen the effectiveness of its AML/CFT regime. Since the adoption of its MER in October 2020, the DRC has made progress on some of the MER’s recommended actions including making confiscation of proceeds of crime a policy priority. The DRC will work to implement its FATF action plan by: (1) finalising the NRA on ML and TF and adopting an AML/CFT national strategy; (2) designating supervisory authorities for all DNFBP sectors, and developing and implementing a risk-based supervision plan; (3) adequately resourcing the FIU, and build its capacity to conduct operational and strategic analysis; (4) strengthening the capabilities of authorities involved in the investigation and prosecution of ML and TF; and (5) demonstrating effective implementation of TF and PF-related TFS. 

GIBRALTAR

(Statement from June 2022)

  • In June 2022, Gibraltar made a high-level political commitment to work with the FATF and MONEYVAL to strengthen the effectiveness of its AML/CFT regime. Since the adoption of its MER in December 2019, Gibraltar has made progress on a significant number of its MER’s recommended actions, such as completing a new national risk assessment, addressing the technical deficiencies in relation to BO-related record keeping, introducing transparency requirements for nominee shareholders and directors, strengthening the financial intelligence unit, and refining its ML investigation policy in line with risks. Gibraltar should work on implementing its action plan, including by: (1) ensuring that supervisory authorities for non-bank financial institutions and DNFBPs use a range of effective, proportionate, and dissuasive sanctions for AML/CFT breaches; and (2) demonstrating that it is more actively and successfully pursuing final confiscation judgements, through criminal or civil proceedings based on financial investigations.

HAITI

  • In June 2021, Haiti made a high-level political commitment to work with the FATF and CFATF to strengthen the effectiveness of its AML/CFT regime. Haiti should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) completing its ML/TF risk assessment process and disseminating the findings; (2) facilitating information sharing with relevant foreign counterparts; (3) addressing the technical deficiencies in its legal and regulatory framework that impede the implementation of AML/CFT preventive measures and implementing risk-based AML/CFT supervision for all financial institutions and DNFBPs deemed to constitute a higher ML/TF risk; (4) ensuring basic and beneficial ownership information are maintained and accessible in a timely manner; (5) ensuring a better use of financial intelligence and other relevant information by competent authorities for combatting ML and TF; (6) addressing the technical deficiencies in its ML offence and demonstrating authorities are identifying, investigating and prosecuting ML cases in a manner consistent with Haiti’s risk profile; (7) demonstrating an increase of identification, tracing and recovery of proceeds of crimes; (8) addressing the technical deficiencies in its TF offence and targeted financial sanctions regime; and (9) conducting appropriate risk-based monitoring of NPOs vulnerable to TF abuse without disrupting or discouraging legitimate NPO activities.

JAMAICA

  • In February 2020, Jamaica made a high-level political commitment to work with the FATF and CFATF to strengthen the effectiveness of its AML/CFT regime. Jamaica should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) including all FIs and DNFBPs in the AML/CFT regime and ensuring adequate, risk-based supervision in all sectors; (2) taking appropriate measures to prevent legal persons and arrangements from being misused for criminal purposes, and ensuring that accurate and up-to-date basic and beneficial ownership information is available on a timely basis to competent authorities; and (3) implementing a risk-based approach for supervision of the NPO sector to prevent abuse for TF purposes.
  • The FATF expresses concern that Jamaica failed to complete its action plan, which fully expired in January 2022. The FATF strongly urges Jamaica to swiftly demonstrate significant progress in completing its action plan by February 2023 or the FATF will consider next steps if there is insufficient progress.

JORDAN

  • Since October 2021, when Jordan made a high-level political commitment to work with the FATF and MENAFATF to strengthen the effectiveness of its AML/CFT regime. Jordan has taken steps towards improving its AML/CFT regime, including by strengthening its legal and operational TF-related TFS framework, increasing capacity for risk-based DNFBP supervision, making basic and beneficial ownership information accessible by competent authorities, maintaining statistics on ML investigations and prosecution and strengthening its legal framework with respect to confiscation. Jordan should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) completing and disseminating the ML/TF risk assessments of legal persons and virtual assets; (2) Improving risk based supervision and applying effective, proportionate, and dissuasive sanctions for noncompliance; (3) Conducting training and awareness raising programs for DNFBPS on their AML/CFT obligations, particularly with regard to filing and submitting STRS; (4) Maintaining comprehensive and updated basic and beneficial ownership information on legal persons and legal arrangements; (5) Pursuing money laundering investigations and prosecutions, including through parallel financial investigations, for predicate offences in line with the risk identified in the NRA; (6) Monitoring and effectively supervising the compliance of FIs and DNFBPS with TFS obligations; and (7) Developing and implementing a risk-based approach for supervision of the NPO sector to prevent abuse for TF purposes.

MALI

  • In October 2021, Mali made a high-level political commitment to work with the FATF and GIABA to strengthen the effectiveness of its AML/CFT regime. Mali should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) implementing the national strategic AML/CFT action plan in line with the NRA; (2) developing and starting to implement a risk based approach for the AML/CFT supervision of all FIs and higher risk DNFBPs and demonstrating effective, proportionate and dissuasive sanctions for noncompliance; (3) conducting a comprehensive assessment of ML/TF risks associated with all types of legal persons; (4) increasing the capacity of the FIU and the LEAs and enhancing their cooperation on the use of financial intelligence; (5) ensuring relevant competent authorities are involved in investigation and prosecution of ML; (6) strengthening the capacities of relevant authorities responsible for investigation and prosecution of TF cases; (7) establishing a legal framework and procedures to implement TFS related to TF and PF; and (8) implementing a risk-based approach for supervision of the NPO sector to prevent abuse for TF purposes.  

MOROCCO

  • In February 2021, Morocco made a high-level political commitment to work with the FATF and MENAFATF to strengthen the effectiveness of its AML/CFT regime. At its October 2022 plenary, the FATF has made the initial determination that Morocco has substantially completed its action plan and warrants an on-site assessment to verify that the implementation of Morocco’s AML/CFT reforms has begun and is being sustained, and that the necessary political commitment remains in place to sustain implementation in the future. Morocco has made the following key reforms, including: (1) improving risk-based supervision and taking remedial actions and applying effective, proportionate and dissuasive sanctions for non-compliance; (2) strengthening its TFS framework and monitoring FIs and DNFBP’s compliance with TFS obligations; (3) undertaking and sharing the results of the risk assessment on the misuse of all types of legal persons with the private sector and the competent authorities; (4) increasing the diversity of suspicious transactions reporting; and (5) establishing asset seizing and confiscation procedures.
  • The FATF will continue to monitor the COVID-19 situation and conduct an on-site visit at the earliest possible date. 

MOZAMBIQUE

  • In October 2022, Mozambique made a high-level political commitment to work with the FATF and ESAAMLG to strengthen the effectiveness of its AML/CFT regime. Since the adoption of its MER in April 2021, Mozambique has made progress on some of the MER’s recommended actions to improve its system including by finalising its NRA and strengthening its asset confiscation efforts. Mozambique will work to implement its FATF action plan by: (1) ensuring cooperation and coordination amongst relevant authorities to implement risk-based AML/CFT strategies and policies; (2) conducting training for all LEAs on mutual legal assistance to enhance the gathering of evidence or seizure/confiscation of proceeds of crime; (3) providing adequate financial and human resources to supervisors, developing and implementing a risk-based supervision plan; (4) providing adequate resources to the authorities to commence the collection of adequate, accurate and up-to-date beneficial ownership information of legal persons; (5) increasing the human resources of the FIU as well as increasing financial intelligence sent to authorities; (6) demonstrating LEAs capability to effectively investigate ML/TF cases using financial intelligence; (7) conducting a comprehensive TF Risk Assessment and begin implementing a comprehensive national CFT strategy; (8) increasing awareness on TF and PF-related TFS; and (9) carrying out the TF risk assessment for NPOs in line with the FATF Standards and using it as a basis to develop an outreach plan.

PANAMA

  • Since June 2019, when Panama made a high-level political commitment to work with the FATF and GAFILAT to strengthen the effectiveness of its AML/CFT regime, Panama has taken important steps towards improving its AML/CFT regime, including by ensuring effective, proportionate, and dissuasive sanctions in response to AML/CFT violations. However, Panama should continue to take urgent action to fully address remaining measures in its action plan as all timelines have already expired in January 2021. Panama should therefore continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) ensuring adequate verification, of up-to-date beneficial ownership information by obliged entities and timely access by competent authorities, establishing effective mechanisms to monitor the activities of offshore entities, and further implementing the specific measures to prevent the misuse of nominee shareholders and directors; and (2) demonstrating its ability to investigate and prosecute ML involving foreign tax crimes.
  • The FATF again expresses significant concern that Panama failed to complete its action plan, which fully expired in January 2021. The FATF strongly urges Panama to swiftly complete its action plan by February 2023 or the FATF will consider calling on its members and urging all jurisdictions to apply enhanced due diligence to business relations and transactions with Panama.  

PHILIPPINES

  • Since June 2021, when the Philippines made a high-level political commitment to work with the FATF and APG to strengthen the effectiveness of its AML/CFT regime, the Philippines has taken steps towards improving its AML/CFT regime, including by demonstrating that appropriate measures are being taken with respect to the NPO sector and implementing supervision for targeted financial sanctions. The Philippines should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) demonstrating that effective risk-based supervision of DNFBPs is occurring; (2) demonstrating that supervisors are using AML/CFT controls to mitigate risks associated with casino junkets; (3) enhancing and streamlining LEA access to BO information and taking steps to ensure that BO information is accurate and up-to-date; (4) demonstrating an increase in the use of financial intelligence and an increase in ML investigations and prosecutions in line with risk; (5) demonstrating an increase in the identification, investigation and prosecution of TF cases; and (6) enhancing the effectiveness of the targeted financial sanctions framework for both TF and PF by demonstrating that DNFBPs understand their obligations. 

SENEGAL

  • Since February 2021, when Senegal made a high-level political commitment to work with the FATF and GIABA to strengthen the effectiveness of its AML/CFT regime, Senegal has taken steps towards improving its AML/CFT regime, including by ensuring consistent understanding of ML/TF risks across relevant authorities through training and outreach, and seeking MLA and other forms of international cooperation. Senegal should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) improving compliance by detecting AML/CFT violations and imposing effective, proportionate and dissuasive sanctions against non-compliant entities; (2) updating and maintaining comprehensive beneficial ownership information on legal persons and arrangements and strengthening the system of sanctions for violations of transparency obligations; (3) strengthening the authorities understanding of TF risks and enhancing capacity and support for LEAs and prosecutorial authorities involved in combatting TF in line with the 2019 TF National Strategy; and (4) implementing an effective TFS regime related to TF and PF as well as risk-based monitoring and supervision of NPOs.
  • The FATF notes Senegal’s continued progress across its action plan, however all deadlines have now expired and work remains. The FATF encourages Senegal to continue to implement its action plan to address the above-mentioned strategic deficiencies as soon as possible. 

SENEGAL

  • Since February 2021, when Senegal made a high-level political commitment to work with the FATF and GIABA to strengthen the effectiveness of its AML/CFT regime, Senegal has taken steps towards improving its AML/CFT regime, including by ensuring consistent understanding of ML/TF risks across relevant authorities through training and outreach, and seeking MLA and other forms of international cooperation. Senegal should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) improving compliance by detecting AML/CFT violations and imposing effective, proportionate and dissuasive sanctions against non-compliant entities; (2) updating and maintaining comprehensive beneficial ownership information on legal persons and arrangements and strengthening the system of sanctions for violations of transparency obligations; (3) strengthening the authorities understanding of TF risks and enhancing capacity and support for LEAs and prosecutorial authorities involved in combatting TF in line with the 2019 TF National Strategy; and (4) implementing an effective TFS regime related to TF and PF as well as risk-based monitoring and supervision of NPOs.
  • The FATF notes Senegal’s continued progress across its action plan, however all deadlines have now expired and work remains. The FATF encourages Senegal to continue to implement its action plan to address the above-mentioned strategic deficiencies as soon as possible. 

SYRIA

  • Since February 2010, when Syria made a high-level political commitment to work with the FATF and MENAFATF to address its strategic AML/CFT deficiencies, Syria has made progress to improve its AML/CFT regime. In June 2014, the FATF determined that Syria had substantially addressed its action plan at a technical level, including by criminalising terrorist financing and establishing procedures for freezing terrorist assets. While the FATF determined that Syria has completed its agreed action plan, due to the security situation, the FATF has been unable to conduct an on-site visit to confirm whether the process of implementing the required reforms and actions has begun and is being sustained. The FATF will continue to monitor the situation, and will conduct an on-site visit at the earliest possible date. 

TANZANIA

  • In October 2022, Tanzania made a high-level political commitment to work with the FATF and ESAAMLG to strengthen the effectiveness of its AML/CFT regime. Since the adoption of its MER in April 2021, Tanzania has made progress on some of the MER’s recommended actions to improve its system including by developing legal framework for TF and TFS and disseminating FIU strategic analysis. Tanzania will work to implement its FATF action plan by: (1) improving risk-based supervision of FIs and DNFBPs, including by conducting inspections on a risk-sensitive basis and applying effective, proportionate, and dissuasive sanctions for non-compliance; (2) demonstrating authorities’ capability to effectively conduct a range of investigations and prosecutions of ML in line with the country’s risk profile; (3) demonstrating that LEAs are taking measures to identify, trace, seize, and confiscate proceeds and instrumentalities of crime; (4) conducting a comprehensive TF Risk Assessment and begin implementing a comprehensive national CFT strategy as well as demonstrating capability to conduct TF investigations and pursue prosecutions in line with the country’s risk profile; (5) increasing awareness of the private sector and competent authorities on TF and PF-related TFS; and (6) carrying out the TF risk assessment for NPOs in line with the FATF Standards and using it as a basis to develop an outreach plan.

TÜRKIYE

  • Since October 2021, when Türkiye made a high-level political commitment to work with the FATF to strengthen the effectiveness of its AML/CFT regime, Türkiye has taken further steps towards improving its AML/CFT regime, including by increasing the human resources at the FIU to conduct analysis and pursuing a number of domestic designations under UNSCR 1373 to target terrorist financing in line with Türkiye’s risk profile. Türkiye should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) increasing on-site inspections by supervisors across all sectors, commensurate with risk; (2) enhancing the use of financial intelligence to support ML investigations and increasing proactive disseminations by the FIU; (3) undertaking more complex money laundering investigations and prosecutions; (4) setting out clear responsibilities and measurable performance objectives and metrics for the authorities responsible for recovering criminal assets and pursuing terrorism financing cases and using statistics to update risk assessments and inform policy; (5) conducting more financial investigations in terrorism cases, prioritising TF investigations and prosecutions related to UN-designated groups, and ensuring TF investigations are extended to identify financing and support networks; (6) concerning targeted financial sanctions, pursuing outgoing requests to third-countries related to UN-designated groups, in line with Türkiye’s risk profile; and (7) to fully implement a risk-based approach to supervision of non-profit organisations to prevent their abuse for terrorist financing, taking steps to ensure that audits conducted are risk-based, that supervision does not disrupt or discourage legitimate NPO activity such as fundraising, and that sanctions applied are proportionate to any violations.
  • The FATF continues to monitor Türkiye’s oversight of the NPO sector. Türkiye is urged to demonstrate the implementation of the risk-based approach to supervision of NPOs in line with the FATF Standards.

UGANDA

  • Since February 2020, when Uganda made a high-level political commitment to work with the FATF and ESAAMLG to strengthen the effectiveness of its AML/CFT regime, Uganda demonstrated progress, including completing the ML/TF risk assessment of legal persons and arrangements. Uganda should continue to work to implement its action plan to address its strategic deficiencies, including by: (1) developing and implementing risk-based supervision of FIs and DNFBPs; (2) ensuring that competent authorities have timely access to accurate basic and beneficial ownership information for legal entities; (3) demonstrating LEAs and judicial authorities apply the ML offence consistent with the identified risks; (4) establishing and implementing policies and procedures for identifying, tracing, seizing and confiscating proceeds and instrumentalities of crime; and (5) addressing the technical deficiencies in the legal framework to implement PF-related targeted financial sanctions. The FATF continues to monitor Uganda’s oversight of the NPO sector to encourage the application of the risk-based approach to supervision of NPOs in line with the FATF Standards and mitigate unintended consequences.
  • The FATF strongly urges Uganda to swiftly implement its action plan to address the above-mentioned strategic deficiencies as soon as possible as all deadlines expired in May 2022.

UNITED ARAB EMIRATES

  • Since February 2022, when the United Arab Emirates (UAE) made a high-level political commitment to work with the FATF and MENAFATF to strengthen the effectiveness of its AML/CFT regime, the UAE demonstrated positive progress, including by providing additional resources to the FIU to strengthen the FIU analysis and provide financial intelligence to LEAs and the Public Prosecutors for combating of high-risk ML threats.
  • The UAE should continue to work to implement its FATF action plan by: (1) demonstrating through case studies and statistics a sustained increase in outbound MLA requests to help facilitate investigation of TF, ML, and high-risk predicates; (2) enhancing and maintaining a shared understanding of the ML/TF risks between the different DNFBP sectors and institutions; (3) showing an increase in the number and quality of STRs filed by FIs and DNFBPs; (4) ensuring a more granular understanding of the risk of abuse of legal persons and, where applicable, legal arrangements, for ML/TF; (5) demonstrate greater use of financial intelligence to pursue high-risk ML threats; and demonstrating a sustained increase in effective investigations and prosecutions of different types of ML cases consistent with UAE’s risk profile; and (6) proactively identifying and combating sanctions evasion, including by demonstrating a better understanding of sanctions evasion among the private sector.

YEMEN

  • Since February 2010, when Yemen made a high-level political commitment to work with the FATF and MENAFATF to address its strategic AML/CFT deficiencies, Yemen has made progress to improve its AML/CFT regime. In June 2014, the FATF determined that Yemen had substantially addressed its action plan at a technical level, including by: (1) adequately criminalising money laundering and terrorist financing; (2) establishing procedures to identify and freeze terrorist assets; (3) improving its customer due diligence and suspicious transaction reporting requirements; (4) issuing guidance; (5) developing the monitoring and supervisory capacity of the financial sector supervisory authorities and the financial intelligence unit; and (6) establishing a fully operational and effectively functioning financial intelligence unit. While the FATF determined that Yemen has completed its agreed action plan, due to the security situation, the FATF has been unable to conduct an on-site visit to confirm whether the process of implementing the required reforms and actions has begun and is being sustained. The FATF will continue to monitor the situation, and conduct an on-site visit at the earliest possible date.

JURISDICTIONS NO LONGER SUBJECT TO INCREASED MONITORING BY THE FATF

Nicaragua

  • The FATF notes Nicaragua’s progress in improving the elements of its AML/CFT regime covered by its action plan. Nicaragua has addressed technical deficiencies to meet the commitments of its action plan regarding strategic deficiencies in the areas that the FATF identified in February 2020. Nicaragua is therefore no longer subject to the FATF’s increased monitoring process.
  • However, the FATF is strongly concerned by the potential misapplication of the FATF Standards resulting in the suppression of Nicaragua’s non-profit sector. Nicaragua should continue to work with GAFILAT to improve further its AML/CFT regime, including by ensuring its oversight of NPOs is risk-based and in line with the FATF Standards. Nicaragua is strongly encouraged to continue cooperating with GAFILAT on this issue.

Pakistan

  • The FATF welcomes Pakistan’s significant progress in improving its AML/CFT regime. Pakistan has strengthened the effectiveness of its AML/CFT regime and addressed technical deficiencies to meet the commitments of its action plans regarding strategic deficiencies that the FATF identified in June 2018 and June 2021, the latter of which was completed in advance of the deadlines, encompassing 34 action items in total. Pakistan is therefore no longer subject to the FATF’s increased monitoring process.
  • Pakistan will continue to work with APG to further improve its AML/CFT system.