Is there a list of high risk "watch" countries that I can obtain? I don't mean OFAC's list of sanctioned countries. Does what I'm talking about exist?

FATF's NCCT list and countries subject to a FinCEN Advisory are good places to start.

Thank you very much.

The problem with "High Risk" countries is that there are many definitions and viewpoints of "High Risk."

The days are gone when we could just point to the FATF NCCT list because, let's face it, that list has dwindled down to two entire countries. I think we can all agree that there are more than 2 high risk countries on the globe.

You may want to take a look at the State Department's list of Major Money Laundering Countries:

http://www.state.gov/p/inl/rls/nrcrpt/2005/vol2/html/42388.htm

and other items contained in the 2005 report:

http://www.state.gov/p/inl/rls/nrcrpt/2005/vol2/html/
The only problem with this list is that among the countries of "Primary Concern" are:

USA
United Kingdom
France
Germany
Japan

and so on.....

You need to consider a few factors in deciding which countries are going to be "High Risk" for your institution:

Your familiarity with the customer that has transactions involving that country.

Your familiarity with the counterparty in that country.

Your familiarity with what is "normal" and what is not normal for that country.

The volume and velocity of activity involving that country.


One bank may be entirely familiar with their customers and their counterparties for wires going to/coming from UAE and they have thoroughly vetted these transactions. For another bank, a wire going to UAE would raise a 5 alarm fire bell.

In developing any such list for your institution, I recommend reading the report and applying the analysis to your particular situation and customer base. I don't believe anyone can have one "magic bullet" list that fits all institutions.

Thank you

Bonnie,
How did you know that the NCCT list had changed? I need to keep up with this stuff, but I didn't know the list had changed. If it wasn't for BOL, I would be in the dark most of the time.

The last post was me, I thought I was logged in. Sorry.

I looked on FATF's website:

http://www.fatf-gafi.org

on the right hand side, click on "Current NCCT List"

The FATF update was included in BOL's 10/19 Compliance Briefing. You can sign up to receive email notice of each day's compliance news. It is a great way to keep up to speed on these issues. I am sure the link is on the Home page.