The FATF Blacklist
is the common shorthand
description for the Financial Action Task Force
of "Non-Cooperative Countries or Territories" (NCCTs); that is,
countries which it perceives to be non-cooperative in the global
fight against money laundering
non-appearance on the blacklist is perceived to be a mark of
approbation for Offshore
(or "tax havens") who are sufficiently well
regulated to meet all of the FATF's criteria, in practice the list
encompasses a large proportion of countries that do not operate as
offshore financial centres.
The term non-cooperative is sometimes criticised as misleading, as
a number of the countries which have appeared on the list from time
to time appear, not because they deliberately propagate a culture
which is perceived to assist money laundering, but because they
simply lack the infrastructure or resources to cope with relatively
sophisticated financial criminals who try to operate there.
The first report
The plenary list was published in June 2000,
and fifteen countries initially appeared on
the list as being regarded as uncooperative in the fight against
- The Cayman Islands
- Cook Islands
- Marshall Islands
- Saint Kitts and Nevis
- Saint Vincent and the
The initial list met much criticism from professionals experienced
in the offshore sector. The designation of the Cayman Islands as
non-cooperative was thought to be harsh, particularly as the 2000
report itself acknowledged that "the Cayman Islands has been a
leader in developing anti-money laundering programmes throughout
the Caribbean region. It has served as president of the Caribbean
Financial Action Task Force, and it has provided substantial
assistance to neighbouring states in the region. It has
demonstrated co-operation on criminal law enforcement matters, and
uncovered several serious cases of fraud and money laundering
otherwise unknown to authorities in FATF member states."
The second report
In the second report, in 2001 (including a supplemental report in
September) a further eight countries were designated as
The FATF produces annual reports, designated countries that go onto
and come off the list.
The general trend has been towards
countries coming off the list, as there is an obvious incentive for
countries to tighten up areas criticised in the FATF reports as not
meeting the required international standards. To date, 21 countries
have been de-listed, and only 8 countries have been added since the
additional list (interestingly, none of which were offshore jurisdictions
The seventh report
The seventh list, published in June 2006, listed only the following
country as non-cooperative:
The eighth report
The following countries were listed as uncooperative tax havens by
in their 2009 report.
The current state of the list: 3 European countries
August 2007, the OECD has blacklisted Andorra, Liechtenstein and Monaco.
On 22 October 2008 at an OECD meeting in Paris, 17 countries led by
France and Germany have decided to draw up a new blacklist of tax
havens. The OECD has been asked to investigate around 40 new tax
havens in the world where undeclared revenue is hidden and which
host many of the non-regulated hedge funds that have come under
fire during the 2008 financial crisis.
France and other countries called on the Organization for Economic
Cooperation and Development (OECD) to specifically add Switzerland to a blacklist of countries which encourage tax
Where the FATF feels that a country is not making sufficient to
improve its regulation it may recommend "counter measures" against
such countries. To date it has only done so against three
countries: Myanmar, Nauru and Ukraine. However, counter measures
have been withdrawn from all three, and as at July 2006 there are
no counter measures in effect against any country.
- Jeremy Hetherington-Gore (n.d.), The Cayman Islands - Paradise Regained?.