Policies & Issues

AML Alert: Check lists of countries with deficiencies

Policies & IssuesFeb 06, 2016

AML Alert: Check lists of countries with deficiencies

The Jewelers Vigilance Committee advises that companies monitor the Financial Action Task Force’s lists of countries that aren’t completely cooperative with international anti-money laundering efforts. 

One of the risks to consider when implementing an anti-money laundering program is the location of your counterparties, both vendors and customers. Some countries have more vigorous and cooperative engagement with international AML efforts than others.  


Suzan R. Flamm (suzan@jvclegal.org) is assistant general counsel of the Jewelers Vigilance Committee

Because of that, it is critical that companies check watch lists that indicate the level of AML compliance of various countries. The Financial Action Task Force (FATF), an inter-governmental body that promotes AML compliance--as well as efforts to combat terrorist financing--maintains such lists.  

Companies in the jewelry industry should determine, on a regular basis, whether any of their trading partners, accounts or distribution channels are located in countries that appear on current FATF lists.  If they are, the next step is to assess the AML risks of doing business with the listed companies.  

FATF maintains different lists of “High-Risk and Non-Cooperative Jurisdictions,” depending on the nature of the particular country’s AML/CFT deficiency, and whether the country is working with FATF to make corrections.  

It is very important to be aware of these lists, which are updated regularly, as they include countries that produce precious stones, metals and/or finished jewelry.  For current information be sure to check FATF’s website.

The FATF lists, as of February 2015, are detailed below.  

Jurisdictions for which a FATF call for action applies
The first, and most serious, list is of jurisdictions that are subject to a FATF call for action.  

In some cases, FATF has asked its members in the international community to apply countermeasures against countries on this list to protect the international financial system from significant risks of money laundering and terrorist financing.  There are currently two countries on the list that fall into this category.  Both are currently the subject of U.S. sanction programs:
-- Iran
-- North Korea 

The other countries on this first list, while not subject to a call for countermeasures, have AML/CFT deficiencies and have not made much progress in addressing them.  

FATF calls on its members to consider the risks arising from the deficiencies. This means that the shortcomings should be seriously evaluated when conducting an AML risk assessment involving companies or accounts based in the countries, or distribution channels through the countries. The countries in this category are:
-- Algeria
-- Ecuador
-- Myanmar (Note that,

separately from AML/CFT considerations, a U.S. executive order bans the importation of rubies and jadeite from this country.)

Jurisdictions engaged in an ongoing process with FATF
The second FATF list is of countries that have AML deficiencies, but that have agreed to an action plan and have committed to work with FATF to make improvements.  

The countries currently on this list are:
--Afghanistan
--Angola
--Guyana
--Indonesia
--Iraq
--Lao PDR
--Panama
--Papua New Guinea
--Sudan
--Syria
--Yemen

One country on this list has been identified as not having made sufficient progress: Uganda.

When conducting an AML risk assessment involving companies or accounts based in any of these countries, or distribution channels through these countries, the fact that the jurisdictions have AML/CFT deficiencies should be considered.

The risk assessment should also take into account that the listed countries are working with FATF to make improvements, and whether or not they are deemed to be making sufficient progress.

Several countries had been on this second list as recently as fall 2014 but are no longer subject to FATF’s compliance process.  Those countries include: Albania, Cambodia, Kuwait, Namibia, Nicaragua, Pakistan and Zimbabwe.

Remember that AML compliance requires the periodic review of government watch lists that identify suspect entities and individuals and that identify countries with deficient AML/CFT practices, such as the FATF lists discussed here.  

You can easily access the lists at JVCLegal.org by clicking “US & Int’l Lists & Forms” on the drop-down menu under the “AML” tab.  

For questions about your anti-money laundering obligations, contact the JVC at askamlexpert@aol.com or 212-997-2002.  Or, visit the website for information about our U.S. PATRIOT Act Compliance Kit and our AML testing services.

Michelle Graffis the editor-in-chief at National Jeweler, directing the publication’s coverage both online and in print.

The Latest

Tacori bezel-set diamond bands
EditorsJul 29, 2025
Out & About: Visiting Tacori’s Design Studio in LA

Senior Editor Lenore Fedow learned a lot when she took a behind-the-scenes factory tour with the jewelry brand earlier this year.

Mighty Fierce Audacious Necklace, Sandy Rubin Aziza Necklace, Koulianos Designs Illuminations Shield Pendant
Events & AwardsJul 29, 2025
Melee The Show Welcomes 15 New Designers

The first-time exhibitors, set to debut at the New York City show, share a devotion to craftsmanship, storytelling, and material integrity.

Auctim emerald auction
SourcingJul 29, 2025
Auctim to Offer 7.3M+ Carats of Rough Emeralds

The online auction house’s September sale will feature rough Brazilian emeralds of various qualities.

rio-article photo-diamond.jpg
Brought to you by
Taking the Moment Head On: How Rio Grande Champions the Present & Future of Fine Jewelry

As a leading global jewelry supplier, Rio Grande is rapidly expanding and developing new solutions to meet the needs of jewelers worldwide.

AGS Board President for 2025-2026 Alexis Padis
MajorsJul 29, 2025
Alexis Padis Re-Elected AGS Board President

She’ll lead an executive committee consisting of President-Elect Bryan Moeller, Mitchell Clark, Bill Farmer, and Larry Rickert.

Weekly QuizJul 25, 2025
This Week’s Quiz
Test your jewelry news knowledge by answering these questions.
Take the Quiz
Nanis Ipanema Collection Campaign
CollectionsJul 28, 2025
Nanis Brings a New Palette to ‘Ipanema’

A new edition of the Italian brand’s “Ipanema” collection has debuted with gemstones that evoke Brazil’s breathtaking views.

Kevin O’ Leary and George Mayer of The 1916 Company
MajorsJul 28, 2025
The 1916 Company Partners with ‘Shark Tank’ Star’s Watch Insurance Platform

The retailer will refer its customers to WonderCare, founded by venture capitalist and watch collector Kevin O’Leary.

an instructor and a student in a bench jewelry classroom
Brought to you by
Investing in the Next Generation of Bench Jewelers

The Seymour & Evelyn Holtzman Bench Scholarship from Jewelers of America returns for a second year.

Sissy’s new Little Rock store
IndependentsJul 28, 2025
Sissy’s Log Cabin to Open Flagship in Arkansas

The jeweler’s largest store yet is set to open in Little Rock next fall.

Jemma Wynne Forme Toggle Necklace
CollectionsJul 25, 2025
Piece of the Week: Jemma Wynne’s ‘Forme’ Necklace

Anne Hathaway was seen wearing the toggle necklace three times while filming scenes for “The Devil Wears Prada 2.”

September Hong Kong jewelry show
Events & AwardsJul 25, 2025
Pre-Registration Open for September Hong Kong Show

Jewellery & Gem World Hong Kong is scheduled for Sept. 15 to 21, and buyer pre-registration will be available until Sept. 7.

Bulgari Celestial Mosaic spinel necklace
FinancialsJul 25, 2025
LVMH Sales Slip in H1 Amid ‘Prevailing Uncertainties’

Renovations at Tiffany & Co. stores ate into profits in the company’s watch and jewelry division.

Mark and Candy Udell
Events & AwardsJul 24, 2025
2 Retailers to Receive 2026 Gem Award for Lifetime Achievement

Mark and Candy Udell of London Jewelers will receive the honor at the 24th annual Gem Awards next March.

De Beers marine mining vessel the SS Nujoma
SourcingJul 24, 2025
De Beers Sees Diamond Production Sink 36% in Q2

While struggles continue at the mining and trading end of the pipeline, consumer demand for diamond jewelry is holding steady.

Francesca Villa Fantasia Collection The Crab Pendant, The Mermaid Pendant, Keep Dancing Seahorse Pendant, Keep Dancing Ladybug Pendant, Secret Dreams Pendant, The Puffer Fish Takes Flight Pendant
CollectionsJul 24, 2025
Francesca Villa Adds Dimension to Her Intaglio Characters

The “Fantasia” jewelry collection turns the intaglio animals from her “Close Encounters” collection into 3D characters.

Breitling’s special Eagles Super Bowl watch on gold bracelet
WatchesJul 24, 2025
Breitling Drops Super Bowl Watch Honoring the Philadelphia Eagles

The special Classic Avi Chronograph 42 with an Eagles-green dial is limited to 59 pieces, a nod to the Super Bowl Philadelphia just won.

Stock image of crime scene tape
CrimeJul 23, 2025
JSA Warns of Violent String of Smash-and-Grabs in California

JSA has received reports of mobs swarming jewelry stores, driving cars into the storefront or smashing through the windows.

Silvia Furmanovich Kasmir Collection Carnelian Bracelet and Sketch
CollectionsJul 23, 2025
Silvia Furmanovich’s ‘Kashmir’ Collection Is a Tribute to Northern India

The “Kashmir” collection features centuries-old craft techniques made in collaboration with the region’s master papier-mâché artisans.

Bench jeweler holding a bracelet and a tool
IndependentsJul 23, 2025
Montreal’s Ecksand Eyes Move to SoHo

Creative Director Erica Bianchini shared why the jeweler is looking to expand into the U.S. and how it’s putting Canadian craftsmanship on the map.

LAFD Fire Station 44 and Fire Station 16
IndependentsJul 23, 2025
IJO Raises Nearly $37K for LA Fire Relief

Two Los Angeles Fire Department stations plan to use the donations to upgrade their equipment and tools.

A Vanitas by Hannah Martin and Guy Berryman Sothebys
CollectionsJul 22, 2025
Jewelry With a Rock ‘n’ Roll Aesthetic Heads to Sotheby’s London

Next week, the auction house will kick off a selling exhibition of jewelry by British artist Hannah Martin and Coldplay’s Guy Berryman.

Cover of the book “Flawless: Inside the Largest Diamond Heist in History”
SourcingJul 22, 2025
Antwerp Diamond Heist Documentary Coming to Netflix

“Stolen: Heist of the Century” is based on “Flawless,” the book about the middle-of-the-night theft, and will debut on Netflix in August.

Emmanuel Raheb
ColumnistsJul 22, 2025
The Gifting Gap: How to Market Jewelry Beyond the Holidays

Emmanuel Raheb shares the top five gifting moments outside of major holidays that jewelers should build marketing campaigns around.

NY Now
Events & AwardsJul 22, 2025
NY Now’s Summer Market Returns in August

The wholesale trade show’s Luxury Lifestyle section will showcase established and emerging jewelry designers.

Jeweler setting a diamond into a ring
MajorsJul 21, 2025
Rio Grande Expands Personalization Offerings

As demand for custom jewelry grows, the company is expanding its services to support retailers.

National Associate of Jewelry Appraisers Logo
Events & AwardsJul 21, 2025
NAJA’s 2025 ‘Ace It’ Conference To Go Virtual

The mid-year conference for jewelry and watch appraisers is slated for Aug. 9 to 10 on Zoom.

Jacquie Aiche graduated turquoise beaded necklace
TrendsJul 21, 2025
Amanda’s Style File: Graduated With Honors

Graduated stones make for elevated tennis-style pieces and dramatic statement necklaces.

×

This site uses cookies to give you the best online experience. By continuing to use & browse this site, we assume you agree to our Privacy Policy