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FinCEN Updates FATF Jurisdiction Risk List — Financial Institutions Must Re-Calibrate Enhanced Due Diligence

Due DiligenceFinCEN Updates FATF Jurisdiction Risk List — Financial Institutions Must Re-Calibrate Enhanced Due Diligence

FinCEN issued an advisory informing U.S. financial institutions of FATF’s February 2026 plenary outcomes, which updated both the Jurisdictions Under Increased Monitoring and High-Risk Jurisdictions Subject to a Call for Action lists.

Iran and North Korea remain on the call-for-action list, subject to countermeasures. Burma/Myanmar remains on the increased monitoring list with a FATF caveat that enhanced due diligence should not disrupt legitimate humanitarian flows.

For compliance programs, the FATF update carries immediate operational requirements: institutions must review their correspondent banking policies, CDD risk assessments, and transaction monitoring rules against the updated jurisdiction lists, ensuring that customers, counterparties, and transaction flows involving newly listed or re-listed jurisdictions are subject to heightened scrutiny.

The FinCEN advisory also reminds institutions of their SAR filing obligations when transactions involving these jurisdictions exhibit suspicious indicators — even where the underlying business appears legitimate. Separately, FinCEN’s February 26, 2026 proposed rule seeking to sever Swiss bank MBaer Merchant Bank AG from the U.S. financial system — for alleged financial support to actors linked to Russia and Iran — illustrates how Section 311 special measures continue to be deployed as a targeted enforcement tool against foreign financial institutions that enable sanctions evasion.

By FCCT Editorial Team

Disclaimer: The views expressed in this article are independent views solely of the author(s) expressed in their private capacity.

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