FINTRAC’s 2025 Advisory on High-Risk Jurisdictions and Sanctions

On July 9, 2025, the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) issued an advisory based on the Financial Action Task Force (FATF) statements from June 13, 2025. This advisory guides reporting entities on managing risks tied to countries with weak anti-money laundering (AML) and counter-terrorist financing (CTF) systems.

High-Risk Jurisdictions

The FATF identifies the Democratic People’s Republic of Korea (DPRK), Iran, and Myanmar as high-risk, requiring:

• DPRK and Iran: Treat all transactions as high-risk, verify client identities, conduct enhanced due diligence, and report to FINTRAC.
• Myanmar: Assess transactions for suspicious activity and apply enhanced due diligence.

Jurisdictions Under Increased Monitoring

The FATF’s “grey list” includes countries like Algeria, Bolivia, and South Africa, which are addressing AML/CTF deficiencies. Reporting entities should apply risk-based due diligence for transactions involving these jurisdictions.

Jurisdictions Removed from Monitoring

Croatia, Mali, and Tanzania have been delisted from the grey list due to significant progress in their AML/CTF frameworks.

Terrorist Financing and Sanctions Evasion

• Islamic State and Afghanistan: Submit Listed Person or Entity Property Reports for transactions linked to these entities and assess for terrorist financing risks.
• Russia: Treat all transactions as high-risk due to its invasion of Ukraine, with enhanced due diligence and reporting for sanctions evasion.
• Middle East: Monitor transactions for potential money laundering or terrorist financing risks.

Key Takeaways

Reporting entities must strengthen compliance programs, focusing on due diligence and sanctions evasion monitoring, as mandated since August 19, 2024. For full details, see the FINTRAC advisory.