ANTI-MONEY LAUNDERING AND PREVENTION OF TERRORISM
AND KNOW YOUR CLIENT MANUAL
ANTI-MONEY LAUNDERING AND PREVENTION OF TERRORISM STATEMENT
- 1. Statutory and regulatory obligations to prevent money laundering are to be met in full and are to be applied as the minimum standard.
- 2. Belega Limited (the ‘Company’) will do its outmost in order to minimize the risk of the Company’s offering being abused for the purposes of
laundering funds associated with criminal activity.
- 3. The Company will not commence or continue relationships with Clients whose conduct gives rise to suspicion of involvement with illegal activities. The Company will seek to terminate any Client relationship where the Client’s conduct gives reasonable cause to believe or suspect involvement with illegal activities. Any such termination shall follow the reporting of the suspicion to the relevant authorities and thereafter shall be undertaken in conjunction with the relevant authorities and in accordance with the custom and practice to avoid any risk of committing a tipping-off offence.
- 4. The Company’s procedures will be based upon the regulatory framework and subsequent guidance issued by the Malta Financial Services Authority (the “MFSA”) and / or the Financial Intelligence Analysis Unit (the “FIAU”) as appropriate and they will be in line with the relevant laws of Malta which may be amended from time to time. On the 31st October 2018, the FIAU published a Consultation Document on the application of Anti-Money Laundering and Countering the Funding of Terrorism Obligations to the Virtual Financial Assets Sector (the “Consultation Document”). Pursuant to the Consultation Document and the Virtual Financial Assets Act, 2018, (the “VFA Act”) the issuer of tokens is to be considered a subject person in terms of applicable laws. This manual has therefore been prepared in terms of the current AML provisions in place (4th AML Directive) and has taken note of the Consultation Document. This manual may therefore need to be updated upon the entry into force of any other regulations or guidelines issued by the MFSA or FIAU.
- 5. Any term not defined in this document shall have the meaning ascribed to it in the relevant Terms, which shall apply thereto unless the context requires otherwise.
N.B. THE FIFTH ANTI-MONEY LAUNDERING DIRECTIVE, DIRECTIVE (EU) 2018/843 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL OF 30 MAY 2018 AMENDING DIRECTIVE (EU) 2015/849 ON THE PREVENTION OF THE USE OF THE FINANCIAL SYSTEM FOR THE PURPOSES OF MONEY LAUNDERING OR TERRORIST FINANCING, AND AMENDING DIRECTIVES 2009/138/EC AND 2013/36/EU, APPROVED ON THE 30TH OF MAY, 2018 SHALL BE IMPLEMENTED BY MEMBER STATES WITHIN 18 MONTHS. THE COMPANY SHALL ENSURE THAT IT IS COMPLIANT WITH THE NEW LAW WHEN IT HAS BEEN TRANSPOSED DOMESTICALLY. THIS COULD AFFECT THE COMPANY’S RELATIONSHIP WITH THE CLIENT AND AS SUCH THE CLIENT MAY BE REQUIRED TO PROVIDE ADDITIONAL INFORMATION IN RELATION TO SUCH CHANGES. SHOULD THE CLIENT NOT AGREE TO PROVIDE SUCH INFORMATION, OR SHOULD HIS/HER STATUS CHANGE AND S/HE IS NO LONGER ELIGIBLE TO PARTICIPATE, THE COMPANY SHALL SEVER ANY RELATIONSHIP IT MAY HAVE WITH THE CLIENT AND IF APPLICABLE, MAKE ANY REQUIRED REPORTS TO THE RELEVANT AUTHORITIES.
- Prevention of Money Laundering Act, Chapter 373 of the Laws of Malta, regulating among others the prevention and prohibition of money laundering in Malta.
- Anti-Money Laundering refers to a set of procedures, laws and regulations designed to stop the practice of generating income through illegal activities. AML has the same meaning as assigned to it in the Prevention of Money Laundering Act, Chapter 373 of the Laws of Malta and Subsidiary Legislation S.L. 373.01 on the Prevention of Money Laundering and Funding of Terrorism.
- Customer Due Diligence is a procedure whereby a company takes the necessary steps to identify its clients and do background checks on them by obtaining the client’s official documents such as passport/identity card/residence card and a utility bill confirming the residential address.
- Combatting the Funding of Terrorism has the same meaning as assigned to it in the S.L. 373.01 on Prevention of Money Laundering and Funding of Terrorism. The Funding of Terrorism (the ‘FT’) means the conduct described in articles 328F and 328I both inclusive, of the Criminal Code, Chapter 9 of the Laws of Malta and S.L.373.01 on the Prevention of Money Laundering and Funding of Terrorism.
- Any natural or juridical person who is participating or intends to participate in the Offering, either on its own behalf or on behalf of its clients. For avoidance of doubt, this shall include an Investor in the Private Token Offer and/or Token Offer
- Fourth (4th) Anti-Money Laundering and Financing of Terrorism Directive transposed in the domestic law on the 20 December 2017, as may be amended from time to time.
- DLT ASSETS
- Virtual assets as defined in the VFA Act.
- Employees engaged to work full-time and part-time for the Company.
- Financial Intelligence Analysis Unit, a government agency established under the Laws of Malta responsible for the collection, collation, processing, analysis and
dissemination of information with a view to combating money laundering and the funding of terrorism.
- Know Your Customer procedures necessary to assess and monitor client risk and a legal requirement to comply with AML/CFT laws.
- Money Laundering Reporting Officer, responsible to ensure that the COMPANY is compliant on all AML and CFT aspects. The appointment of the MLRO is prescribed in terms of Laws of Malta.
- An offer made by the Company, through a reward-based fundraising event, to accept contributions towards its project, which contributions will be rewarded with an allocation of a determinate amount of DLT Assets.
- Politically Exposed Persons, including all persons who fulfil a prominent public function as described in the Directive.
- PROHIBITED INVESTORS
- Natural or legal persons defined as Prohibited Investors in the Terms and for the purpose of this manual, shall also apply to PEPs and to Financial Action Task Force (FATF) jurisdictions as prescribed in Annex I to this Manual.
- RECEIPT OF DLT ASSETS
- The transfer of the DLT Assets to the COMPANY from Clients for the participation in the Offering.
- Suspicious Transaction Report, submitted by the MLRO of the Company to the FIAU when he has reasonable grounds to suspect that the transaction which is being carried out is related to a money laundering offence or a terrorist activity financing offence.
- VFA ACT
- The Virtual Financial Assets Act, Chapter 590 of the laws of Malta
- 1. Virtual Financial Assets (‘VFA’) are influencing the financial services landscape operating outside the traditional financial system. A VFA is defined as ‘any form of
digital medium recordation that is used as a digital medium of exchange, unit of account or store of value and that is not (a) electronic money; (b) a financial instrument; or (c) a virtual token. In the light of these developments, the scope of anti-money laundering/countering the funding of terrorism has extended to this area as well.
- 2. Malta has recognised the heighted risks associated with VFAs and has brought all VFA service providers within the scope of its domestic AML/CFT framework, stating risks that they may face due to the nature of VFAs, and related products, services and activities.
- 3. The purpose of this manual is to describe in detail the internal procedures set by the Company to prevent Money Laundering and Funding of Terrorism. These procedures strive to ensure that the Company does its utmost to prevent and limit fraud and money laundering activity by carrying out CDD on its Clients and having clear procedures to follow during the entire relationship with its Clients, from the moment of the on-boarding and registration until the closure of the relevant transaction/s.
- 4. The Company will put an emphasis on adopting a risk-based approach in its AML/CFT obligations and in its CDD requirements in view of the Directive and as required for the Offering.
- 5. The Company shall obtain a confirmation from its MLRO that all the AML/CFT requirements are satisfied and the Company has the adequate systems in place to identify suspicious transactions and to draw up suspicious transactions reports. This shall be part of the Compliance Certificate that the Company shall draw and submit to the Authority on an annual basis.
- 6. An independent auditor, engaged by the Company, shall draw up a report on annual basis as a review of the operations of the Company from an AML/CFT perspective and confirm that the AML/CFT/KYC systems of the Company are in place.
- 7. In the implementation of this manual, and always in compliance with applicable laws, the Company may use the services of third party entities as may be required from time to time.
ANTI-MONEY LAUNDERING AND COMBATING FUNDING OF TERRORISM PROCEDURES
- 8. Money laundering (the “ML’) is the process by which criminals attempt to conceal the true criminal origin and ownership of the proceeds of their criminal activities. It is the process by which the proceeds of crime are converted into assets which appear to have a legitimate origin. If undertaken successfully, it allows criminals to
maintain control over and to enjoy these proceeds.
- 9. The requirement to launder the proceeds of crime through the financial system and through other means is vital for the success of criminal operations. Those involved, seek to exploit the facilities of the world’s financial institutions if they are to benefit from the proceeds of their criminal activities. The increased integration of the world’s financial systems, the removal of barriers to the free movement of capital and technological developments have enhanced the ease with which criminal money can be laundered, thereby complicating the tracing process.
- 10. In addition, assets based on digital ledger technology have gathered increasing attention as being financially innovative. However, this can also be a new tool for criminals, terrorist financiers and other sanctions evaders to move and store illicit funds.
- 11. While consistent regulations on AML/CFT is lacking in the field of digital ledger technology assets, FATF have issued Guidance for a Risk Based Approach to Virtual Currencies (convertible virtual currencies exchangers) in June 2015 and the FIAU issued a Consultation Document on the Application of AML and CFT obligations to the virtual financial assets sector in October 2018, however no regulation is yet implemented in relation to this matter.
- 12. Estimates for the amount of money laundered worldwide are quoted from time to time. The International Monetary Fund estimated that two to five percent of the global economy involved laundered money. Though the margin between those figures is huge, even the lower estimate underlines the seriousness of the problem governments have pledged to address. However, in reality it is impossible to produce a reliable estimate of the amount of money laundered. The amount of money laundered each year amounts to billions of Euros and poses a significant concern for governments. As a result, governments and international bodies have undertaken efforts to prevent and apprehend money launderers.
- 13. ML traditionally occurs in three steps:
- a. Placement - involves cash being introduced into the financial system by some means.
- b. Layering - involves carrying out complex financial transactions in order to camouflage the illegal source, and
- c. Integration - entails acquiring wealth generated from the transactions of the illicit funds.
- 14. This rather simplistic approach does not necessarily reflect every type of ML operation and depending on the circumstances of the particular case, one or more of the traditional steps may not take place. Indeed, the definition of ML focuses on the conversion, concealment, disguise, acquisition, possession, use and retention of property knowing or even suspecting that it is derived from criminal activity.
- 15. Funding of Terrorism (‘FT’) and ML are conceptual opposites: whereas ML aims at converting proceeds deriving from criminal activity into seemingly legitimate assets for re-integration into the financial system, FT is not concerned with the source of the funds but rather the scope for which these funds are used.
- 16. FT is the process by which terrorists (whether individuals or organisations) are funded in order to be able to carry out acts of terrorism. FT involves the receipt, collection or provision of funds whether originating from legitimate or illegitimate sources, for use by individuals or organizations engaged in terrorist activity. It does not require the funding of a specific terrorist act or that a terrorist act is actually committed and it also includes the funding of all activities of terrorists, including legitimate activities. The primary goal of individuals or entities involved in the financing of terrorism is therefore not to conceal the sources of the money but to support terrorist activity.
- 17. The primary goal of AML/CFT procedures and controls, when effectively implemented, is to mitigate the adverse effects of criminal economic activity and promote integrity and stability in financial markets.
- 18. In order to reduce the possibility that the Company’s operation is used as a medium for ML/FT, the following steps shall be taken:
- i. Follow established parameters as set out in this manual;
- ii. Monitor any requests from a Client in order to identify irregular patterns;
- iii. All transactions are to be checked to prevent ML/FT activity;
- iv. The Company shall provide all the necessary training to its Employees on AML/CFT;
- v. The Company shall appoint an MLRO which will have the duties as assigned to him/her under this manual.
- 19. MLRO Duties
- i. The MLRO is responsible for developing the necessary policies and procedures, and deliver training and education to the Employees of the Company. The Directors and the MLRO shall ensure that internal procedures are kept up to date and the MLRO is to ensure that he is up to date with new AML requirements and developments.
- ii. Developing and maintaining this manual in line with evolving statutory and regulatory obligations, experience and advice from enforcement agencies.
- iii. Representing the Company with all external agencies and in any other third-party enquiries in relation to ML prevention or compliance.
- iv. Ensuring that all departments of the Company are complying with this manual and therefore monitoring operations and the development of this manual to this end.
- v. Undertaking the internal review of all suspicions of ML/FT and determining whether or not such suspicions have substance and require disclosure to the FIAU.
- vi. Keeping contact between the Company and the authorities in respect of routine reports and also any specific investigations.
- All Employees must report any suspicions of ML/FT to the MLRO who will in turn escalate the reports as necessary. The Company will report any suspicious transactions by means of a STR which could involve ML/FT to the FIAU.
CLIENT ACCEPTANCE PROCEDURE:
- 20. Prior to acceptance of a new Client, the Company needs to carry out the following procedure in all cases:
- i. Send to the Client relevant information with respect to the Offering being done by the Company;
- ii. Carry out the standard KYC procedures;
- iii. Check whether the Client comes from a high-risk jurisdiction as outlined in Annex I;
- iv. Carry out a check to ensure that a Client is not a Prohibited Investor;
STANDARD KYC PROCEDURE:
- 21. The standard KYC procedure on every Client shall be carried out at the Client acceptance stage. The standard KYC procedure is carried out in two separate phases which are the identification and the verification of the Client. The first phase which is identification of the Client entails collection of the basic information on the Client including name, surname, date of birth, address, identity card/passport number and nationality, and where appropriate, IP addresses and other device identifiers. The Company shall also conduct searches on world check or another independent online search engine. The second phase is the verification of such collected information against official documentation.
- 22. The Company shall seek to determine whether the Client is acting on his own behalf or on behalf of someone else, in which case the KYC procedure shall be undertaken in relation to both persons. The following can all assist with such determination:
- a. from where customer instructions are being received;
- b. source of funds;
- c. the destination of funds;
- d. payment references or rationale that do not appear to relate to the purported customer; and
- e. any unusual delay in answering questions due to the purported customer having to refer to a third party.
- 23. The Company shall also obtain the address of the wallet/account number used to receive or transfer the DLT Assets during the Offering, and then proceed to verify that such wallet or account actually belongs to the Client. Such verification shall be carried out prior to the receipt or transfer of DLT Assets to that particular wallet or account.
- 24. Due to the risky nature of DLT Assets, the Company shall ensure that particular care is taken before the receipt of DLT Assets in order to be able to take a decision as to whether to onboard the Client or otherwise.
- 25. A certified true copy of the following official documents needs to be submitted during the standard KYC procedure for the identification and verification of a natural person:
- i. a valid passport /residence card/ identity card/driving license; and
- ii. for the purpose of verifying the residential address: a recent statement from a recognised credit institution/a recent utility bill/official conduct certificate or any other government-issued document which is not older than three months.
- 26. Certified true copies of the below original documents need to be submitted where the Client is a legal person:
- i. certificate of incorporation;
- ii. certificate of good standing;
- iii. he most recent version of the Memorandum and Articles of Association or other equivalent statutory document;
- 27. The certification of these documents can either be carried out by a lawyer/notary or in the case where a Client is a legal person, such certification may be done by the Registry of Companies or equivalent entity in the respective jurisdiction, or else by an officer of that legal person. In view of the fact that the Offering in relation to DLT Assets is carried out online, it will be possible to carry out a certification of the documents here above mentioned via commercial electronic data providers or via video conference as allowed by the Implementing Procedures published from time to time by the FIAU.
- 28. The Company shall also verify through the documents obtained during the standard KYC procedure that a Client is over eighteen (18) years of age upon registration, since minors will not be onboarded.
- 29. Where the Client is not present, the Company shall apply an enhanced KYC procedure as explained below. Verification can be carried out through the use of commercial electronic data providers or via video conferencing as allowed by the Implementing Procedures published from time to time by the FIAU.
- 30. Where the Company accepts DLT Assets as payment, the Company shall:
- a. check the wallet address/account for negative information in the public domain; and
- b. use distributed leger analytical tools to, inter alia, detect potentially fraudulent transactions and other suspicious activity (e.g.: the DLT Assets were used on the darkweb or in connection with a ransomware attack).
STANDARD KYC PROCEDURE:
- 32. The enhanced KYC procedure shall be carried out in cases when a risk assessment raises medium risk and high risk flags during the risk assessment. The enhanced KYC procedure shall also be carried out for interface risk applications from the Clients. There could be various types of risks identified during the risk assessment stage including customer risk, economic activity risk and interface risk. The following all present various degrees of risk which have to be assessed on a case-by-case basis:
- i. whether the type of client is likely to pose higher-than-average risk;
- ii. risk indicators such as the client background, country of origin, business activities, products, linked accounts or activities and public or other high-profile positions;
- iii. Client is reluctant, secretive or evasive, or provides insufficient, incomplete, suspicious or false information or information that cannot be verified;
- iv. use of various layers of intermediaries, proxies, unverifiable IP address or geographical location, disposable email address or mobile number, ever changing devices used to conduct transactions;
- v. use of anonymiser software, mixers or similar systems which tend to obscure the true identity of a person;
- vi. unusual patterns of transaction activity (e.g. volumes, velocity, structuring to avoid detection/reporting obligations, source, destination);
- vii. the transaction involves the use of a disproportional amount of accumulated savings, bearer cheques or cash, or large financial transactions;
- viii. the potential for cybercriminals to launch ransom-ware attacks in light of the combination of decentralisation and anonymity;
- ix. accepting higher risk digital currencies which reduce traceability and allow for anonymity, thus increasing the chance that they were used for illicit activity;
- x. the source of funds is unusual, for example: (a) funding from a third party who has no apparent connection with the customer or for which there is no legitimate explanation; (b) funds received from a foreign country when there is no apparent connection between the country and the customer; (c) wealth accumulated from and/or funds received from high-risk countries.
- Medium and High Client Risk
- In case of medium client risk, further documentation in addition to the usual documentation must be requested in order to verify the identity and residence of the Client (in the case of a natural person). This could be in the form of additional official documents proving the identity and residency. A verification of the certifier should also be obtained, together with apostilization of the documents. When the Client is a legal person a web search on the Client shall be undertaken, and a bank and/or professional reference shall be requested.
- Medium Economic Activity Risk
- In case of medium economic activity risk, the Client shall be asked to present proof of source of his/her wealth and proof of source of funds unless the Company is able to apply alternative measures which are equally effective in addressing the risk identified. The following documentation shall be sufficient on a case-by-case basis: a recent tax return declaration endorsed by the relevant competent authority, certified true copy of the purchase agreements of assets, certified true copy of an inheritance deed, share certificates/accounts of business profit and loss, together with a professional reference from a bank manager or an employee of the bank in an equivalent position.
- High Economic Activity Risk
- In case of high economic activity risk, the Company will request further information in addition to the documentation provided and further supporting documentation from the Client regarding his/her business activity. This refers to the proof of previous involvement in the industry, confirmation of previous employment, confirmation of previous customers/suppliers of business relationships, clean police conduct certificate (not older than 3 months) etc.
The documentation collected for the purpose of determining the source of wealth should allow the Company to determine:
- i. how the Client generated his wealth; and
- ii. how he derived the funds being used to carry out the particular transaction;
- iii. whether the transaction makes sense within the context of the information collected.
The documentation collected for the purpose of determining the source of funds should allow the Company to determine how these were obtained by the Client, for example
- i. in the case of fiat – an account or credit or debit card issued by a reputable bank or payment institution set up in a reputable jurisdiction;
- ii. in the case of DLT Assets – mining (evidenced through electricity bills or receipt of purchase of equipment), or evidence of previous transactions effected by the Client
to determine the activity that led to the Client being in possession of these DLT Assets.
- Interface Risk
- When the Client is not physically present for identification purposes, the Company is not in a position to establish that the Client is actually the person he purports to be without resorting to adequate measures to compensate for the higher risk. Therefore, in addition to the identification and verification of identity measures to be carried out in accordance with the standard KYC procedure, the Company shall apply the following measures:
- i. establish the identity of the Client by using additional documentation and information;
- ii. ask the Client to provide additional documentation to confirm the personal details of the Client as per the Standard KYC Procedure
- 33. Documents obtained in terms of the Enhanced KYC procedure must be additional to documents obtained when carrying out the Standard KYC procedure. This measure is intended to ensure that the identity details appearing on the documents used for verification would have been obtained from different sources.
- 34. The documents provided must be verified or certified using supplementary measures if needed. The Company must exercise caution when accepting certified copies of documents, especially where such documents originate from a country or territory perceived to represent a higher risk. In such case, the Company must request a copy of the necessary identification documents of the certifier/apostilisation of the documents.
- 35. Once all the requested documents are obtained and necessary verifications have taken place, the Company will confirm the Client for acceptance via email.
- 36. After the successful Standard KYC Procedure and/or Enhanced KYC Procedure have been undertaken, the Company and the Client shall enter into an agreement wherein the Client shall provide all the necessary information relative to his wallet. A registration process shall be undertaken by the Client to start participating in the Offering of the Company.
- 37. The Company shall not onboard Clients who are Prohibited Investors.
- a. The Company shall not onboard PEPs as Clients i.e. those who have been entrusted with one of the following functions:
- i. Heads of State, Heads of Government, Ministers and Deputy and Assistant Ministers and Parliamentary Secretaries;
- ii. Members of Parliament;
- iii. Members of the Courts or of other high-level judicial bodies whose decisions are not subject to further appeal, except in exceptional circumstances;
- iv. Members of courts of auditors, audit committees or of the boards of central banks;
- v. Ambassadors, charge d’affaires and other high ranking officers in the armed forces;
- vi. Members of the administration, management or boards of state-owned corporations;
- b. The immediate family members of PEPs shall not be onboarded as Clients, and this includes:
- i. the spouse, or any partner recognised by national law as equivalent to the spouse;
- ii. the children and their spouses or partners; and
- iii. the parents;
- c. The Company shall not onboard Clients coming from Financial Action Task Force (FATF) jurisdictions as prescribed in Annex I of this Manual.
- ONGOING MONITORING
- a) review and monitor the transactions of Clients on an ongoing basis;
- b) collect IP addresses and other device identifiers where appropriate;
While reviewing transactions, attention should be paid to:
- c) complex and unusually large transactions;
- d) unusual patterns of transactions which have no apparent economic or visible lawful purpose;
- e) transactions which are out of character or inconsistent with the history, pattern, or normal operation of the activities;
- f) insufficient, incomplete or suspicious information provided by the Client;
- g) use of proxies, unverifiable IP address or geographical location, disposable email address or mobile number, ever changing devices used to conduct transactions
- 39. When the Company knows, suspects or has reasonable grounds to suspect that a transaction may be related to ML/FT, or that a person may have been, is or may be connected with ML/FT, or that ML/FT has been, is being or may be committed or attempted, the Company shall, through its MLRO, as soon as is reasonably practicable, but not later than five working days from when the suspicion first arose, disclose that information, supported by the relevant identification and other documentation, to the FIAU.
- 40. The Company and its Employees shall refrain from carrying out a transaction that is suspected or known to be related to ML/FT until the Company has informed the FIAU and, where to refrain in such a manner is not possible or is likely to frustrate efforts of investigating or pursuing the beneficiaries of the suspected ML/FT operations, the Company shall accordingly inform the FIAU immediately once the transaction is affected and by not later than twenty-four hours from execution of the transaction. If this is the case, the MLRO shall inform the FIAU of reasons for taking such a decision and document these accordingly.
- 41. If an Employee knows, suspects or has reasonable grounds to suspect that a transaction may be related to ML/FT, or that a person may have been, is or may be connected with ML/FT, or that ML/FT has been, is being or may be committed or attempted they should discreetly report such suspicion or knowledge directly to the MLRO. The MLRO may then file an STR with the FIAU.
- 42. In no instance should the Employee disclose or give any indication to the Client about a suspicion as this will likely prejudice an investigation. Tipping off is a serious criminal offence.
- Reporting can be done as follows:
Through the FIAU Website
Other Contact details:
Tel: (356) 21231333
Fax: (356) 21231090
ANNEX I: FATF HIGH RISK JURISDICTIONS
- The below is the current Financial Action Task Force (FATF) list of jurisdictions that are identified as presenting a high risk of ML and/or FT. This list should be updated regularly and can be obtained from http://www.fatf-gafi.org/topics/high-riskandnon-cooperativejurisdictions/
Jurisdictions subject to a FATF call on its members and other jurisdictions to apply counter-measures to protect the international financial system from the on-going and substantial money laundering and terrorist financing (ML/FT) risks emanating from the jurisdictions.
Democratic People’s Republic of Korea (DPRK)
Jurisdictions with strategic AML/CFT deficiencies that have not made sufficient progress in addressing the deficiencies or have not committed to an action plan developed with the FATF to address the deficiencies. The FATF calls on its members to consider the risks arising from the deficiencies associated with each jurisdiction, as described below.