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Did the regulators in the big countries not notice the FATF had changed its NCCT list?

11 October 2002: the Financial Action Task Force removes Russia, Niue and the Marshall Islands from the FATF NCCT list. This is no surprise to member countries who have to agree and the major movers all make up their minds in advance of the meeting which is, in this respect, a rubber stamp and publicity event.

Sometime in November 2002: FinCEN, the USA's Financial Crimes Enforcement Network and a representative at the FATF, announces that its "advisories" (warning notices) about the three countries are withdrawn.

The "advisories" are tantamount to an indictment of the countries and require US financial services businesses to take special care in dealing with the country named. The continuation of the notice beyond the date of removal from the list is unacceptable.

But the USA is not the only one to be tardy. The UK and others did not take urgent steps to withdraw the notices they issued to their regulated businesses, either.

The impact on banks and others within those countries can be serious: which is the whole point of the list.

To influence the FATF and then not immediately act on its recommendations is the same as bribing the referee and then continuing to hit your opponent after the bell. And self proclaimed leading countries should behave better.

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