小收煞: FATF 的灰名單和黑名單

Source:

https://www.fatf-gafi.org/en/countries/detail/Hong-Kong-China.html

前言：地下水湧上地面

地震前後的常見現象：大量的地下水突然湧上地面，令路面液化，車輛無法通過。又或者地下水突然大量流失，導致路陷，路面出現一個很大的洞，令車輛跌下去。地面上的道路系統無法使用，人車卻步。那個地區要圍封起來，直到修復為止。

粵語水為財，地下水等於原本在地下金融系統流通的黑錢（犯罪收入），而剛過去的 2025 年是大量中國黑錢湧上地面的一年（提示：錢志敏+陳志+蘇炳海）。數量之多，肉眼可見，路人皆知。地下金融系統出事，令地上的合法金融系統受影響，外國勢力有理由說三道四，採取懲罰性措施，影響貿易和投資。過去一年，主流傳媒找到不少證據，證明跨國犯罪集團利用香港（的商業房地產或高級住宅或上市公司或金融機構）洗黑錢。於是有網上的財經評論員預言：香港會被 FATF 列入灰名單 (Grey list)。

FATF 的灰名單和黑名單

FATF 的全名是 Financial Action Task Force，是負責制定反洗錢法規的國際組織，有 40 個國家是會員，總部設於巴黎。組織的宗旨是製訂反洗錢法規，進行相關的調查和研究，以及透過 Mutual Assessment 和 Onsite inspection 定期監察各國的執行情況。如果某國的執行情況未如理想，未能落實符合國際標準的反洗錢法規，又或者有證據顯示某國已經淪為洗黑錢中心，就會被 FATF 開名，被定義為 a Jurisdiction under Increased Monitoring (Grey list) 或 High Risk Jurisdiction subject to a Call for Action (Black list)。

根據 FATF 網頁提供的資料，被列入灰名單 (Grey list) 的國家包括剛剛被美國用軍事行動生擒（遠洋捕撈）總統（馬杜羅）然後接管內政的委內瑞拉 (Venezuela)、越南 (Vietnam) 和避稅天堂英屬處女島 The Virgin Islands (UK) 。被 FATF 列入灰名單 (Grey list) 意味著該國需要 Increased monitoring。跨國金融機構要處理來自這些國家的交易，合規 (Compliance) 成本會增加。如果稍後該國採取行動，作出改善，情況令 FATF 滿意，將會被除名。

被列入黑名單 (Black list) 的國家包括北韓（Democratic People's Republic of Korea, DPRK) 和 Iran（伊朗）。對於被列入黑名單 (Black list) 的國家，FATF會要求成員國採取適當的回應措施 (Counter measures)。針對被列入黑名單 (Black list) 的北韓 (DPRK) ，FATF 對成員國作出以下建議：

Terminate correspondent relationships with DPRK banks;

Close any subsidiaries or branches of DPRK banks in their countries; and

Limit business relationships & financial transactions with DPRK persons.

簡單地說：金融層面的 Decoupling。北韓和伊朗都是長期被美國制裁的國家，原因大家都懂。伊朗近期因為貨幣貶值，導致惡性通膨，老百姓生活艱難，小商戶和大學生上街，爆發全國性的反政府示威。經濟因素導致政治動盪，令神權政府危在旦夕。美國總統特朗普 (Donald Trump) 公開呼籲伊朗政府不要槍殺人民，否則美國會出手干預。打開口牌？稍後是否會採取軍事行動，還是實施更多的經濟制裁？有待觀察。

FATF ‘toothless’ on Russia

至於同樣被西方世界視為「邪惡軸心」(Axis of evil) 的俄羅斯，情況較為複雜。俄羅斯在2022年2 月底入侵烏克蘭，FATF 於 2023 年 2 月把俄羅斯 suspend membership，但沒有把俄羅斯放入灰名單 (Grey list) 或黑名單 (Black list)。歐盟的成員國的議員形容 FATF ‘toothless’ on Russia，廣東話叫「無牙力」，即是懲罰措施不痛不癢，沒有殺傷力。歐盟委員會 (European Commission) 索性不等 FATF 出手，把俄羅斯視作洗黑錢的高危國家處理，放入自訂的黑名單內。歐盟委員會 (European Commission) 是歐盟的行政機構，負責提出法律草案、執行歐盟政策和管理預算，並維護歐盟的整體利益。請參考《延伸閱讀》部份提供的參考資料。 Anna Stylianou 的貼文解釋此舉對於受歐盟國家法規影響的反洗錢工作人員所帶來的影響。她是外國金融罪案專家，熟悉反洗錢法規。

自從美國總統特朗普 (Donald Trump) 在 2025 年 1 月展開第二個任期以來，美國跟歐盟的關係發生重大變化。歐盟領袖不信美國會在俄羅斯和烏克蘭的和談上扮演真正中立的角色。美國也要求歐盟在國防事務上減少對美國的依賴（提示：The Monroe Doctrine 門羅主義 1823），而歐盟國家也覺得 America has become unpredictable，不可以期望美國會協助歐盟抵擋普京，於是調整策略。從歐盟國家的角度看，想辦法對付洗黑錢的普京白手套，就等於切斷俄羅斯戰爭機器的財政來源，有助自保。本質上，跟提供武器或情報給烏克蘭一樣，都是透過打擊普京來保護自己，是 Part of the same project。長期研究金融罪案的英國記者 Oliver Bullough 這樣說：If the US has stepped back, everyone else needs to step forward. 至於是俄羅斯黑錢停泊熱點的英國，態度比較曖昧，請參考《延伸閱讀》部提供的參考資料，Anna Stylianou 的貼文有提及英國的態度。

對中國和香港的影響

在 FATF 的架構中，香港擁有獨立會籍，香港和中國的評審工作是分開進行的。但是在現實世界中，香港跟中國密不可分。剛過去的 2025 年，香港的洗黑錢問題惡化，情況失控，大量的地下水湧上地面，肉眼可見。主流傳媒找到的證據：陳志（提示：太子集團）和蘇炳海（提示：2023 年 8 月中新加坡執法部門破獲的福建幫 10 人洗黑錢集團成員+恐龍骨收藏家+倫敦豪宅業主）都在香港擁有整棟的商廈。欲知詳情，請上網。都是福建幫，是否巧合，自己想。香港淪為洗黑錢中心，問題的根源是中國因素，也跟香港的政治制度和經濟發展模式有關。

想像一下：如果美國針對中國或香港的制裁行動升級或制度化，變成長期措施，又或者中國或香港因為洗黑錢活動失控而被 FATF 列入灰名單 (Grey list)，甚至是黑名單 (Black list)，會對貿易和投資帶來怎樣的後果？災難性，對不對？到時候，就不止是外資金融機構（及跨國企業）的合規 (Compliance) 成本增加那麼簡單，而是外資跟香港切割，進行金融層面的 Decoupling。至於是否會導致政治動盪或政權更替？自己想。讀到這裡，你也許會這樣想：在鏡頭前跟普京大帝和金三胖一起步上天安門城樓的國家領導人，是否懂經濟？總加速師，名不虛傳。

事情還有更深遠的影響。長期被美國制裁或被 FATF 列入灰名單 (Grey list) 甚至是黑名單 (Black list) 的國家，從事正當產業有困難，更無法進行產業升級，只能「撈偏門」，成為國家級犯罪集團。例如：訓練電腦黑客盜取別國的個人資料或商業機密或加密貨幣，然後在暗網 (Dark Web) 轉移或出售。從事人口販賣或跨國詐騙。用影子船隊 (Shadow Fleet) 在公海上用「船過船」的方式販賣石油（提示：俄羅斯、伊朗和委內瑞拉都用這一招，都是賣石油給中國的產油國）。透過這些活動賺取的黑錢要想辦法漂白，否則難以進入美國主導的國際金融體系。這種國家於是成為洗黑錢專家，習慣依賴犯罪活動賺取收入，支持國家運作，形成惡性循環，難以抽身，聲名狼藉。

這種國家的結局：權貴走資、中產移民、年輕人或上街或入獄或逃亡、外資撤退、產業萎縮、貨幣貶值、經濟崩潰、政治動盪。是否會導致政權更替，就要看時機（提示：反對派領袖拿諾貝爾和平獎）。眼前的委內瑞拉和伊朗，是發展中的真實個案，值得留意。香港和中國是否會走上同一條路，自己想。

延伸閱讀／參考資料：

The FATF

https://www.fatf-gafi.org/en/the-fatf.html

Excerpt: The Financial Action Task Force (FATF) leads global action to tackle money laundering, terrorist and proliferation financing. The 40-member body sets international standards to ensure national authorities can effectively go after illicit funds linked to drugs trafficking, the illicit arms trade, cyber fraud and other serious crimes.

The FATF's decision-making body, the FATF Plenary, meets three times per year and holds countries to account if they do not comply with the Standards. If a country repeatedly fails to implement FATF Standards then it can be named a Jurisdiction under Increased Monitoring or a High Risk Jurisdiction. These are often externally referred to as “the grey and black lists”. The FATF was established in 1989 and is based in Paris.

（推介原因：FATF 的宗旨和運作。）

FATF – What we do

https://www.fatf-gafi.org/en/the-fatf/what-we-do.html

The Financial Action Task Force (FATF) leads global action to tackle money laundering, terrorist and proliferation financing.

The FATF researches how money is laundered and terrorism is funded, promotes global standards to mitigate the risks, and assesses whether countries are taking effective action.

Methods and Trends

FATF continuously monitors how criminals and terrorists raise, use and move funds. As countries put in place effective measures to disrupt illicit financial flows, criminals must find alternative ways to launder their dirty money. FATF regularly publishes reports that raise awareness about the latest money laundering, terrorist financing and proliferation financing techniques so that countries and private sector can take the necessary steps to mitigate these risks.

Identifying high-risk jurisdictions

The FATF holds countries to account that do not comply with the FATF Standards. If a country repeatedly fails to implement FATF Standards then it can be named a Jurisdiction under Increased Monitoring or a High Risk Jurisdiction. These are often externally referred to as “the grey and black lists”.

FATF – High-risk and other monitored jurisdictions

https://www.fatf-gafi.org/en/topics/high-risk-and-other-monitored-jurisdictions.html

Excerpt: Global safeguards to combat money laundering and terrorist financing (AML/CFT) are only as strong as the jurisdiction with the weakest measures. Criminals can circumvent weak AML/CFT controls to successfully launder money or to move assets to finance terrorism through the financial system. A key objective of the FATF is to continually identify jurisdictions with significant weaknesses in their AML/CFT regimes, and to work with them to address those weaknesses. The FATF’s process helps protect the integrity of the international financial system by issuing a public warning about the risks emanating from the identified jurisdictions. These public warnings also put pressure on the identified jurisdictions to address their deficiencies in order to maintain their position in the global economy. Public identification, and the prospect of public identification, encourages countries to swiftly make significant improvements.

FATF – High Risk and other monitored jurisdictions (Grey list)

Paris, 24 October 2025

https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2025.html

Jurisdictions under increased monitoring are actively working with the FATF to address strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing. When the FATF places a jurisdiction under increased monitoring, it means the country has committed to resolve swiftly the identified strategic deficiencies within agreed timeframes and is subject to increased monitoring. This list is often externally referred to as the “grey list”.

"grey list"

Venezuela

Vietnam

the Virgin Islands (UK)

FATF - High-Risk Jurisdictions subject to a Call for Action (Black list)

Paris, 24 October, 2025

https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/Call-for-action-october-2025.html

Excerpt: High-risk jurisdictions have significant strategic deficiencies in their regimes to counter money laundering, terrorist financing, and financing of proliferation. For all countries identified as high-risk, the FATF calls on all members and urges all jurisdictions to apply enhanced due diligence, and, in the most serious cases, countries are called upon to apply counter-measures to protect the international financial system from the money laundering, terrorist financing, and proliferation financing (ML/TF/PF) risks emanating from the country. This list is often externally referred to as the “black list”.

Since February 2020, Iran reported in January, August and December 2024 and August 2025 with no material changes in the status of its action plan.

Given heightened proliferation financing risks, the FATF reiterates its call to apply countermeasures on these high-risk jurisdictions.

"black list"

Jurisdictions subject to a FATF call on its members and other jurisdictions to apply countermeasures

Democratic People's Republic of Korea (DPRK)

Building upon the FATF statements over the past decade, the FATF remains concerned by the DPRK’s continued failure to address the significant deficiencies in its anti-money laundering and combating the financing of terrorism (AML/CFT) regime and the serious threats posed by the DPRK’s illicit activities related to the proliferation of weapons of mass destruction (WMDs) and its financing.

The FATF has continually reiterated since 2011 the need for all countries to robustly implement the targeted financial sanctions in accordance with UNSC Resolutions and apply the following countermeasures to protect their financial systems from the money laundering, terrorist financing, and proliferation financing threat emanating from DPRK:

Terminate correspondent relationships with DPRK banks;

Close any subsidiaries or branches of DPRK banks in their countries; and

Limit business relationships & financial transactions with DPRK persons.

Despite these calls, DPRK has increased connectivity with the internatinoal financial system, which raises proliferation financing (PF) risks, as teh FATF noted in February 2024. this requires greater vigilance and renewed implementation and enforcement of these countermeasures against the DPRK. As set out in UNSCR 2270, DPRK frequently uses front companies, shell companies, joint ventures and complex, opaque ownership structures for the purpose of violating sanctions. As such, FATF encourages its members and all countries to apply enhanced due diligence to the DPRK and its ability to facilitate transactions on its behalf.

FATF also urges countries to adequately assess and account for the increased proliferation financing risk with the greater financial connectivity reported, particularly since the next round of assessments requires countries to adequately assess PF risks under Recommendation 1 and Immediate Outcome 11. The ability to obtain reliable and credible information to support the assessment of PF risks relating to the DPRK is hampered by the recent termination of the 1718 Committee Panel of Experts mandate. Thus, the FATF will monitor the measures to comply with DPRK targeted financial sanctions and the implementation of countermeasures against DPRK.

Iran

The FATF acknowledges Iran’s re-engagement with the FATF as Iran aims to address deficiencies in its AML/CFT regime. In June 2016, Iran provided a high-level political commitment to address those deficiencies through an action plan that expired in January 2018. In October 2019, given Iran’s lack of progress on its action plan, the FATF called upon its members and urged all jurisdictions to: require increased supervisory examination for branches and subsidiaries of financial institutions based in Iran; introduce enhanced relevant reporting mechanisms or systematic reporting of financial transactions; and require increased external audit requirements for financial groups with respect to any of their branches and subsidiaries located in Iran. Since February 2020, given Iran’s failure to fully address its action plan, the FATF has called upon its members and required all jurisdictions to apply effective countermeasures in line with Recommendation 19.

In September 2025, Iran provided an update to the FATF on its ratification of the United Nations Convention against Transnational Organized Crime (Palermo). While the FATF takes note of Iran’s submission and engagement, at this time, the FATF assesses that the reservations Iran has made to Palermo are overly broad and that Iran’s domestic compliance with Palermo is not in line with the FATF standards. The FATF also notes Iran has failed to address the majority of its action plan since 2016.

Considering the United Nations Security Council Resolutions related to Iran’s lack of compliance with its nuclear non-proliferation obligations, the FATF reminds all jurisdictions of their obligations under the FATF standards to address proliferation financing risks emanating from Iran. Additionally, given the ongoing terrorist financing and proliferation financing threats emanating from Iran and as Iran’s action plan remains incomplete, the FATF reiterates its call on its members and urges all jurisdictions to apply effective countermeasures on Iran, including the following:

refusing the establishment of subsidiaries or branches or representative offices of financial institutions from the country concerned or otherwise taking into account the fact that the relevant financial institution is from a country that does not have adequate AML/CFT systems; and

prohibiting financial institutions from establishing branches or representative offices in the country concerned, or otherwise taking into account the fact that the relevant branch or representative office would be in a country that does not have adequate AML/CFT systems.

Iran will remain on the FATF High Risk Jurisdictions Subject to a Call for Action statement until the full Action Plan has been completed. As the FATF previously stated, should Iran ratify and implement the Palermo and Terrorist Financing Conventions, in line with the FATF standards, the FATF will decide on next steps, including whether to suspend countermeasures. The FATF may consider additional next steps if Iran fails to demonstrate additional progress on its action plan.

The FATF strongly encourages Iran to work with the FATF to urgently make further progress on its action plan to fully address: (1) adequately criminalizing terrorist financing, including by removing the exemption for designated groups “attempting to end foreign occupation, colonialism and racism”; (2) identifying and freezing terrorist assets in line with the relevant United Nations Security Council resolutions; (3) ensuring an adequate and enforceable customer due diligence regime; (4) demonstrating how authorities are identifying and sanctioning unlicensed money/value transfer service providers; (5) ratify and implement the TF Convention in line with the FATF standards and ensure that the ratification and implementation of the Palermo Convention is also in line with the FATF standards and clarify the capability to provide mutual legal assistance; and (6) ensuring that financial institutions verify that wire transfers contain complete originator and beneficiary information.

Jurisdiction subject to a FATF call on its members and other jurisdictions to apply enhanced due diligence measures proportionate to the risks arising from the jurisdiction.

FATF - Russian Federation

https://www.fatf-gafi.org/en/countries/detail/Russian-Federation.html

Member since 2003*

* As the Russian Federation's membership to the FATF was suspended in February 2023, the follow-up process has been carried-out by the relevant FATF-style regional body - the Eurasian Group (EAG) - of which the Russian Federation is a member.

The Financial Action Task Force (FATF), the Eurasian Group and MONEYVAL, assessed Russia’s anti-money laundering and counter terrorist financing (AML/CFT) system. The assessment is a comprehensive review of the effectiveness of Russia’s measures and their compliance with the FATF Recommendations. This includes an assessment of its actions to address the risks emanating from UN and domestically designated terrorists and terrorist organisations. The report does not address the justification that led to the domestic designation of an entity as a terrorist or terrorist group or organisation.

The 2023 report below, carried out by EAG, is an analysis of the results achieved by the Russian Federation* between October 2019 and July 2023 in addressing the technical compliance deficiencies noted in the mutual evaluation report. The country has been re-rated on four Recommendations. Six recommendations are rated Compliant and 31 Largely Compliant; the country remains partially compliant on 3 of the 40 Recommendations.

Top EU lawmaker brands FATF ‘toothless’ on Russia, AMLA sets out its four priorities for 2026-27, don’t miss our special webinar on top AFC trends

From Paul O'Donoghue

AMLintelligence.com

2025-12-03

https://www.linkedin.com/comm/pulse/top-eu-lawmaker-brands-fatf-toothless-russia-amla-sets-u3cwe?otpToken=MTMwNjFjZTcxNjI2Y2FjY2JkMjQwNGVkNDAxYWUwYjE4N2NjZDM0NDlhYWI4NzYxNzRjNjAwNmM0NzVlNThmYmY2ZDdkZmEzMWFmOGUxODE1ZGZkZWYyZWRjY2IzZDNiZTFkNjE1MDljZjhmNmU1YTc2YzM1ZSwxLDE%3D

Excerpt: GREETINGS from Brussels where we have been monitoring the appearance of AMLA Chair Bruna Szego at the European Parliament. Given it was her first appearance as AMLA Chair, the MEPs were willing to give her an easy pass, with broad brush questions – focusing on Russia, crypto and fears of narco-states in Europe.

If anything however it was FATF (Financial Action Task Force) which came into the line of fire.

One of the Union’s top lawmakers MEP Isabel Benjumea Benjumea said Europe is "entirely dependent on an inter-governmental body [FATF]… [which has] proved toothless with Russia”.

Benjumea’s words carry a lot of weight in the parliament, given her membership of the powerful ECON committee and the fact she was one of the Rapporteurs who helped designed AMLA. She also belongs to the EPP, the biggest political group in the European Parliament and is known not to mince her words.

The signs are increasingly that Europe will diverge from FATF.

The issue has been bubbling along for years. The EU’s AML blacklist follows FATF which has not acted despite multiple reports which have identified Russia as a key money laundering hub. Indeed another leading MEP, Billy Kelleher pointed out to Ms Szego Russia’s wholesale involvement in money laundering and terror financing.

The situation has worsened since its illegal invasion of Ukraine, with Kremlin-linked criminals going as far as to buy a bank to help the country avoid western sanctions.

Yet for all that, the FATF has still not added Russia to its AML blacklist, instead only suspending the country’s membership.

To date, the EU has followed suit. However, the European Commission is reviewing the issue - and reports in French media say it is soon expected to recommend finally blacklisting Russia.

Such a move would likely increase pressure on the FATF, as Russia’s efforts to launder dirty money have repeatedly hit international headlines.

Anna Stylianou 的貼文

Russia added to the EU’s AML high-risk list: What this means in practice

https://www.linkedin.com/posts/annastylianoucy_russia-added-to-the-eus-aml-high-risk-list-activity-7402247584096083968-R7Hs

Russia added to the EU’s AML high-risk list: What this means in practice

You’ve probably already seen the news:

The European Commission added Russia to the list of high-risk third countries due to strategic deficiencies in its AML/CFT framework.

I’ve decided to write a short breakdown of what this looks like in practice, especially if you work in AML.

The first thing to understand is that: This is a binding decision and directly applicable to all EU regulated entities.

And here’s what makes this decision interesting:

Russia is not on the FATF grey or black list

The UK has not taken a similar position

So why did the European Commission take this decision?

Because the EU has concluded that, despite the lack of FATF or UK designation, Russia still presents a threat to the integrity of the EU financial system.

If you're an AML officer at an EU-regulated institution, here’s what this update requires you to consider:

1. Country risk assessments

Russia must now be treated as a high-risk third country under EU law
Update internal risk scoring, matrices, and policy documents

2. Enhanced due diligence (EDD)

Apply EDD to Russian clients, counterparties, and beneficial owners
Consider indirect links - such as offshore structures or intermediaries
Retain clear documentation of your rationale and decisions

3. Onboarding and KYC process

Russian connections should now trigger additional review steps
Check whether your onboarding process can flag links to Russia properly

4. Transaction monitoring

Revisit typologies that may involve Russia-linked flows
Consider additional monitoring thresholds or alert triggers

5. Internal communication

Inform relevant teams (e.g. onboarding, legal, risk, senior management)
Include this regulatory change in your compliance reporting

6. Governance

Senior management should be informed - and may need to approve changes to customer acceptance criteria or risk appetite.

Listing Russia as a high-risk third country for money

laundering and terrorist financing

European Parliament

Nov 2024

https://www.europarl.europa.eu/RegData/etudes/ATAG/2024/766241/EPRS_ATA(2024)766241_EN.pdf

Listing Russia as a high-risk third country for money laundering and terrorist financing

Despite reported endemic levels of corruption and state-embedded organised crime, as well as risks stemming from Russia's war against Ukraine, the European Union (EU) does not classify Russia as a high-risk third country for money laundering and terrorist financing. During the European Parliament's November I plenary session, the Commission is scheduled to make a statement on its potential listing as such.

The Financial Action Task Force (FATF) 'black' and 'grey' country lists

Efforts to address money laundering internationally include the activities of the Financial Action Task Force (FATF). This inter-governmental body sets anti-money-laundering and countering the financing of terrorism (AML/CFT) standards that have a quasi-global reach. The FATF recommendations have been incorporated into EU law by five successive EU AML directives. Among other things, the FATF identifies jurisdictions having strategic deficiencies in their AML/CFT regimes and classifies them as either 'high-risk jurisdictions subject to a call for action' ('black list') or 'jurisdictions under increased monitoring ('grey list').

EU's independent assessment of grounds for listing a country

Whereas the EU generally complies with the FATF listing, it conducts independent assessments. Articles 9 and 64 of Directive (EU) 2015/849 (the 4th Anti-Money-Laundering Directive) empower the Commission to identify high-risk third countries with strategic deficiencies in their AML/CFT regimes and list them through a delegated act. This power can be revoked at any time by the European Parliament or the Council.

To fulfil its task under these articles, the Commission has developed a methodology for identifying high risk third countries under Directive (EU) 2015/849, which involves several steps. First, the Commission conducts its own EU-specific assessment,using the FATF lists as a starting point. Next, upon identifying a high-risk country, it may adopt a delegated act with the updated list annexed to it. The Commission's general approach is to open a dialogue with the country concerned and list it only if it does not cooperate or fails to implement the agreed benchmarks within a deadline. However, if there is an 'overriding level of risk' that cannot be mitigated through a country's adherence to the EU benchmarks, or,if such risk requires urgent actionin exceptional circumstances, the Commission may immediately identify strategic deficiencies and list the country.The goal of the EU list is to protect the internal market by requiring 'obliged entities', such as banks, to apply 'enhanced due diligence measures' to high-risk countries.

Potential listing of Russia

The FATF blacklisted Russia in 2000, but delisted it in 2002 and accepted it as a full FATF member in 2003. The most recent FATF mutual evaluation report (2019) gave Russia's AML/CFT system an overall positive assessment. Russia subsequently addressed some of the deficiencies highlighted in the report. However, in 2023, the FATF suspended Russia's membership over its war against Ukraine. In February 2024, the FATF reiterated its position, expressing concerns over 'potential risks to the international financial system, including the growing financial connectivity of Russia with countries subject to FATF countermeasures, risks of proliferation financing, and malicious cyber activities and ransomware attacks'. The FATF reportedly deliberated on listing Russia during its October 2024 plenary meeting, with similar elements cited as justification for this action. However, Russia was not included in the updated lists published afterwards. Ukraine's proposal to blacklist it was purportedly rejected by some FATF member countries and 'postponed to gather more evidence'. During the European Parliament's November I plenary session, the Commission is due to make a statement concerning the potential listing of Russia under the EU rules.

EU Expands Sanctions, Targets Russia’s Shadow Fleet

The EU has tightened its sanctions in an effort to pressure Putin into negotiating an end to the war in Ukraine and is prepared to impose even more “massive” sanctions if he refuses to agree to a ceasefire.

Reported by Mariam Shenawy

OCCRP

May 14, 2025

https://www.occrp.org/en/news/eu-expands-sanctions-targets-russias-shadow-fleet?gad_source=1&gad_campaignid=22567027894&gclid=EAIaIQobChMIorD5iJGjkQMVINQWBR1F-RJbEAAYASAAEgKW5fD_BwE

Excerpt: Two months after adopting its 16th sanctions package against Russia, the European Union has backed a 17th round on Wednesday, targeting Russia’s so-called “shadow fleet”—a network of vessels used to evade sanctions and export oil to foreign markets. The new sanctions target 194 ships associated with the shadow fleet, 31 arms supply companies involved in circumventing sanctions, and several banks, according to France's Foreign Minister Jean-Noël Barrot.

Media reports say the package will also include "dozens" of additional individuals linked to Russia’s military and security apparatus. They will be added to the nearly 2,400 people and entities already subject to EU visa bans and asset freezes. The sanctions also cover individuals implicated in cyberattacks, human rights violations, and acts of sabotage in Europe.

European leaders endorsed the latest sanctions in an effort to pressure President Vladimir Putin to engage in negotiations and end the war in Ukraine. Barrot said additional steps would be necessary, as the sanctions so far have failed to deter Vladimir Putin from continuing his war of aggression. “So we must prepare to expand devastating sanctions that could suffocate once and for all Russia's economy,” he told news channel BFM TV.

The package received broad backing from EU officials. European Commission President Ursula von der Leyen wrote on X that the bloc will “keep the pressure high on the Kremlin,” adding, “This war has to end.”

“Sanctions drain Russia’s war chest,” Kallas wrote.

US Department of the Treasury

Treasury Targets Iranian Oil Exports and Shadow Fleet

August 21, 2025

https://home.treasury.gov/news/press-releases/sb0229

WASHINGTON — Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) is further disrupting Iran’s oil exports by imposing sanctions on Greek national Antonios Margaritis, his network of companies, and nearly a dozen vessels involved in Iran’s shadow fleet. Margaritis has leveraged his decades of experience in the shipping industry to illicitly facilitate the transportation and sale of Iranian petroleum. Several other vessels and operators are also being designated today for their role facilitating Iranian oil exports, which generates revenue that contributes to Iran’s advanced weapons programs.

“Today’s action against Margaritis and his network degrades Tehran’s ability to fund its advanced weapons programs, support terrorist groups, and threaten the safety of our troops and our allies,” said Secretary of the Treasury Scott Bessent. “Under the leadership of President Trump, Treasury remains determined to hold accountable all those who seek to aid the Iranian regime and threaten global security."

Today’s action is being taken pursuant to Executive Order (E.O.) 13902, which targets Iran’s petroleum sector. Today’s action also marks the latest round of sanctions targeting Iranian oil sales since the President issued National Security Presidential Memorandum 2 (NSPM-2), instituting a campaign of maximum economic pressure on Iran.

Maintaining pressure on enablers of Iranian oil shipments

Iran continues to rely on an international network of organized, witting actors to sell and transport its oil, which funds the Iranian regime and its terrorist activities in the region. These actors range from complicit individuals personally profiting from the illicit trade to special purpose vehicles that own and deceptively operate vessels transporting Iranian commodities to end users in multiple jurisdictions.

美國再於委內瑞拉附近海域扣押油輪：

由香港公司擁有且未被制裁

撰文：劉耀洋

HK01 (2025-12-21)

https://www.hk01.com/article/60305550?utm_source=01articlecopy&utm_medium=referral

節錄：美國 12 月 20 日再次於委內瑞拉海岸附近的國際水域中扣押一艘油輪，聲稱船隻隸屬於委內瑞拉「影子艦隊」，非法運輸受制裁石油。美媒引述聯合國國際海事組織（International Maritime Organization，IMO）指，該油輪懸掛巴拿馬國旗，也是香港公司世紀海運（Centuries Shipping）擁有的唯一船舶，兩者皆未被制裁。《華爾街日報》及《華盛頓郵報》20 日報道，IMO 資料顯示，涉事油船輪名為「世紀號」（Centuries），懸掛巴拿馬國旗並登記在世紀海運名下，公司及船隻皆未被列入制裁名單。

報道引述原油運輸追蹤網站 TankerTrackers 指，「世紀號」7 日至 11 日期間在委內瑞拉的碼頭裝載了180 萬桶委內瑞拉原油；船舶追蹤公司 Marine Traffic 數據則顯示，油輪船在委內瑞拉裝載原油後，正啟程前往亞洲。《華盛頓郵報》指，「世紀號」於 2020 年 4 月首次被追蹤到，它當時正向中國運送委內瑞拉石油。一名匿名消息人士稱，該油輪這次同樣正為一間總部位於中國的貿易商運輸石油，而該貿易商此前曾多次把委內瑞拉原油運給中國煉油廠。

（推介原因：香港的角色和大陸網民的回應。大陸網民 A 的回應：運往中國的委內瑞拉石油被美國搶走了，中共卻只懂得向台灣發動圍台軍演。大陸網民 B 的回應：不只石油，連總統也搶走了。大陸網民 C 的回應：石油放久了長美軍。）

FATF – Next Round of Mutual Evaluations

https://www.fatf-gafi.org/en/calendars/assessments.html

Excerpt: Sequence of countries currently scheduled to be assessed during the next Round of Mutual Evaluations, against the FATF Methodology 2022. The possible onsite period is indicative and will be adjusted in line with the final mutual evaluation timeline.

China

FATF-APG-EAG

Apr 2019

Jun 2026 (Possible onsite period)

Feb 2027

Hong Kong, China

FATF/APG

Sep 2019

Nov 2029 (Possible onsite period)

Jun 2030

FATF – Mutual Evaluations

https://www.fatf-gafi.org/en/topics/mutual-evaluations.html

Excerpt: FATF mutual evaluations are in-depth country reports analysing the implementation and effectiveness of measures to combat money laundering, terrorist and proliferation financing. The reports are peer reviews, where members from different countries assess another country. Mutual evaluations provide an in-depth description and analysis of a country’s anti-money laundering and counter-terrorist financing system, as well as focused recommendations to further strengthen its system.

During a mutual evaluation, the assessed country must demonstrate that it has an effective framework to protect the financial system from abuse.

Mutual Evaluations have two main components, effectiveness and technical compliance.

The most important part of a mutual evaluation is a country’s effectiveness ratings. This is the focus of an on-site visit by a team of experts to the assessed country. During this visit, the assessment team will require evidence that demonstrates that the assessed country’s measures are working and delivering the right results. What is expected from a country differs, depending on the money laundering, terrorist financing and other risks it is exposed to.

The assessment of technical compliance is also an important part of a mutual evaluation. The assessed country must provide information on the laws, regulations and any other legal instruments it has in place to combat money laundering and the financing of terrorism and proliferation.

The mutual evaluation report is an assessment of a country’s measures to combat money laundering and the financing of terrorism and proliferation of weapons of mass destruction. This includes an assessment of a country’s actions to address the risks emanating from designated terrorists or terrorist organisations. The mutual evaluation report is without prejudice to the status or justification that led to the designation of an entity as a terrorist or terrorist group or organisation.

The FATF conducts peer reviews of each member on an ongoing basis to assess levels of implementation of the FATF Recommendations, providing an in-depth description and analysis of each country’s system for preventing criminal abuse of the financial system.

FATF – China

https://www.fatf-gafi.org/en/countries/detail/China.html

Member since 2007

Excerpt: Since the 2019 assessment of the effectiveness of China's measures to combat money laundering and terrorist financing, the country reported back to the FATF in 2020 and 2021 on the actions taken to strengthen its AML/CFT framework. As a result of this report, the FATF rerated the Country on a number of the 40 Recommendations.

Today, China is compliant on 9 of the 40 Recommendations and largely compliant on 22 of them. It remains partially compliant on 3 Recommendations and non-compliant on 6 Recommendations.

FATF – Hong Kong, China

https://www.fatf-gafi.org/en/countries/detail/Hong-Kong-China.html

Member since 1991

Excerpt: Since the 2019 assessment of Hong Kong, China's measures to tackle money laundering and terrorist financing, the country has taken a number of actions to strengthen its framework.

In line with the FATF Procedures for mutual evaluations, the country has reported back to the FATF on the action it has taken since their mutual evaluation.

Today, Hong Kong, China is compliant on 11 Recommendations and largely compliant on 25. It remains partially compliant on 4 Recommendations.

In 2019, the FATF and the Asia-Pacific Group (APG) jointly assessed the effectiveness of Hong Kong, China's measures to combat money laundering and terrorist financing, and their compliance with FATF Recommendations.

Following this mutual evaluation, Hong Kong, China will report back regularly about its progress in addressing the techical compliance deficiencies. FATF may rerate the country to reflect this progress, but this follow-up process does not focus on effectiveness. The effectiveness of Hong Kong, China's actions to combat money laundering and terrorist financing will be assessed in the 5th round of mutual evaluations.

FATF – Hong Kong, China's progress in strengthening measures to tackle money laundering and terrorist financing

https://www.fatf-gafi.org/en/publications/Mutualevaluations/FUR-Hong-Kong-China-2023.html

Excerpt: 17 February 2023 - Overall, Hong Kong, China has made progress in addressing the technical compliance deficiencies identified in its 2019 Mutual Evaluation, relating to Regulation and supervision of DNFBPs.

The country has been upgraded on one Recommendation.

Recommendation 28 is upgraded from Partially Compliant to Largely Compliant.

Hong Kong, China will remain in regular follow up.

相關的文章：

騙徒版購房通 (Part 1)

2025 年 10 月 3 日

https://xiaoshousha.blogspot.com/2025/10/blog-post.html

騙徒版購房通 (Part 2)

2025 年 10 月 18 日

https://xiaoshousha.blogspot.com/2025/10/blog-post_18.html

騙徒版購房通 (Part 3)

2025 年 10 月 24 日