BaFin Circular 12/2023 (GW)
The BaFin Circular 12/2023 (GW) addresses measures and legal consequences related to countries listed by the EU and FATF due to deficiencies in combating money laundering, terrorism financing, and the financing of proliferation. It is directed at all entities under the supervision of BaFin according to the German Money Laundering Act. The circular establishes:
- Enhanced due diligence and reporting obligations for business transactions involving high-risk countries.
- Specific measures for each listed country to mitigate risks in the international financial system.
- Special monitoring and control measures for certain countries.
- It replaces previous circulars and refers to relevant sanctions and recommendations.
List of Countries by Risk Category:
High-Risk Thrid Countries:
- North Korea
- Iran
- Afghanistan
- Barbados
- Burkina Faso
- Democratic Republic of Congo
- Gibraltar
- Haiti
- Jamaica
- Yemen
- Jordan
- Cayman Islands
- Cameroon
- Mali
- Mozambique
- Myanmar
- Nigeria
- Panama
- Philippines
- Senegal
- South Africa
- South Sudan
- Syria
- Tanzania
- Trinidad and Tobago
- Uganda
- Vanuatu
- United Arab Emirates
- Vietnam
Countries under Increased Monitoring (but with progress):
- Barbados
- Bulgaria
- Burkina Faso
- Democratic Republic of Congo
- Gibraltar
- Haiti
- Jamaica
- Yemen
- Cameroon
- Croatia
- Mali
- Mozambique
- Nigeria
- Philippines
- Senegal
- South Africa
- South Sudan
- Syria
- Tanzania
- Turkey
- Uganda
- United Arab Emirates
- Vietnam