On March 31, 2020, the Financial Action Task Force (FATF) released a report regarding the measures taken by the United States to strengthen their money laundering framework. In their report, FATF found that the United States has been in an enhanced follow-up process following the adoption of its mutual evaluation in 2016, after the 2016 FATF evaluation. In line with the FATF Procedures for mutual evaluations, the country has reported back to the FATF on the actions it has taken since then.
To reflect the United States' progress, the FATF has re-rated the country on “Recommendation 10”, which relates to Customer Due Diligence and Beneficial Ownership tracking. The rating has changed from “Partially Compliant” to “Largely Compliant.”
The report also looks at whether the United States' measures meet the requirements of FATF Recommendations that have changed since the 2016 mutual evaluation. The FATF agreed to maintain the rating of Compliant for Recommendation 2 (National cooperation and coordination), Recommendation 5 (Terrorist financing offense) and Recommendation 21 (Tipping-off and confidentiality). The FATF also maintained the rating of Largely Compliant for Recommendation 7 (Targeted financial sanctions related to proliferation), Recommendation 8 (Non-profit organizations), Recommendation 15 (New technologies) and Recommendation 18 (Internal controls and foreign branches and subsidiaries).
The United States is now compliant on 9 of the 40 Recommendations and largely compliant on 22 of them. It remains partially compliant on 5 of the 40 Recommendations and not compliant on 4 of them. While several of the “not compliant” recommendations relate to “Designated non-financial businesses & professions,” several of the partially compliant recommendations relate to things that would apply to financial institutions like wires, politically exposed persons (PEPs) and suspicious activity. The United States remains in enhanced follow-up and will report back to the FATF on progress to strengthen its implementation of Anti-Money Laundering / Countering the Financing of Terrorism measures.