FATF Mutual Evaluation Scorecard
The United States
US 2016 FATF Mutual Evaluation Report
Key Findings:
- Despite financial institutions having an evolved understanding of ML/TF risks and obligations, the financial sectors still bear most of the burden for required measures under the Bank Secrecy Act.
- The US regulatory framework maintains significant gaps for certain institutions and businesses such as investment advisers, lawyers, real estate agents, trust and company service providers.
- Lack of timely access to accurate, adequate and updated beneficial ownership information, namely Recommendations 24 and 25.
- Aggressive pursuit to investigations and asset confiscation at a federal level, both domestically and abroad. However, there is no uniform approach to state-level AML efforts and forfeiture.
US 2024 FATF Follow-Up Report and Technical Compliance Updates
Key Findings:
- With the US making progress to address technical compliance deficiencies in the 2016 Mutual Evaluation Report (MER) related to Recommendation 24, the US was re-rated on this Recommendation.
- Based on the 2016 MER and the 2022 National Risk Assessments on Money Laundering (NMLRA), a major money laundering method includes creating legal entities without the availability of accurate information about beneficial owners. The US continued to face vulnerabilities and risks associated to the misuse of legal entities to hide and move funds.
- Majority of the opportunities identified for Recommendation 24’s rating criteria were addressed with the enactment of the Corporate Transparency Act (CTA) in January 2021, which mandated existing and newly established businesses to submit beneficial ownership information (BOI) to the Financial Crimes Enforcement Network (FinCEN) under the final BOI Reporting Rule effective January 2024. Some exemptions still apply (e.g. MSBs are exempt but are subject to strong licensing and regulatory oversight by FinCEN), but mainly due to very limited CTA circumstances and conditions. Note: Due to public criticism and legal challenges, in March 2025, FinCEN issued an interim final rule, which redefined “reporting companies” as “foreign reporting companies,” effectively exempting US companies and persons from BOI reporting requirements to FinCEN.
Other FATF Mutual Evaluation Scorecards
Mexico
The scorecard tracks the Mexico 2018 FATF Mutual Evaluation Report and 2022 FATF Follow-Up Report and Technical Compliance Re-Rating Updates.
The Bahamas
The scorecard tracks the Bahamas 2017 FATF Mutual Evaluation Report and 2022 FATF Follow-Up Report and Technical Compliance Updates.
United Arab Emirates
The scorecard tracks the UAE 2020 FATF Mutual Evaluation Report and 2023 FATF Follow-Up Report and Technical Compliance Updates.
Canada
The scorecard tracks the Canada 2016 FATF Mutual Evaluation Report and 2021 FATF Follow-Up Report and Technical Compliance Updates.
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