IRAN TO BE SANCTIONED IN 2019 BY THE FINANCIAL ACTION TASK FORCE (FATF)

If you have reviewed the latest report from the October 17th Plenary Session of the Financial Action Task Force (FATF), you know that the FATF is quite unhappy with Iran's lack of progress regarding the full Action Plan. Although the agency has continued to suspend what it refers to as "countermeasures," it has now warned that the absence of reforms, by February 2019, will result in "further steps to protect against the risks emanating from deficiencies in Iran's AML/CFT regime."

Whether that will mean a return to the legendary FATF Non-Cooperative Countries and Territories List we cannot say, but if Iran continues to flout FATF guidance, there will be some pushback. Iran would be well advised to get with the program before the specified February deadline.

If you have not yet gotten around to reading the October FATF Report, you may access the complete text here. Go to Section 3, Mutual Evaluations and Follow-Up Reviews and Compliance, "Monitoring Iran's actions to address deficiencies in its AML/CFT measures."