HomeCirculars › RBI/2009-10/361

FATF Updates AML/CFT Risk Countries List – March 2010

No longer current — withdrawn, no replacement on file yet
Source: Reserve Bank of India · RBI/2009-10/361 · issued 26 Mar 2010 · ~2 min read
Quick answerRBI directs banks to factor in AML/CFT risks from Iran, Angola, DPRK, Ecuador, Ethiopia, Pakistan, Turkmenistan, and Sao Tome and Principe as per FATF's February 2010 statement. Banks must apply enhanced due diligence or countermeasures based on the risk tier.

What changed

FATF issued a new statement on February 18, 2010, categorizing jurisdictions with strategic AML/CFT deficiencies into three groups: Iran (subject to countermeasures), Angola, DPRK, Ecuador, Ethiopia (no action plan committed), and Pakistan, Turkmenistan, Sao Tome and Principe (previously identified deficiencies remain). RBI updated its earlier November 2009 circular to reflect this revised FATF classification.

What it means for you

Banks and All India Financial Institutions must reassess their exposure and transaction monitoring for entities linked to these eight countries. Iran requires the strictest countermeasures, while the other two groups demand enhanced risk assessment. Failure to adjust AML/CFT controls could expose banks to regulatory action and reputational risk.

Historical instruction — do not use for current compliance. This is what was required at the time; it no longer reflects current RBI requirements. If no replacement rule is linked above, that only means none is recorded on our register yet — it does not prove no later applicable rule exists. Confirm on the official RBI source below.

What banks were required to do at the time

Who it affects

Scheduled Commercial Banks (excluding RRBs), Local Area Banks, All India Financial Institutions, Compliance and AML/CFT teams, Principal Officers

❓ Common questions

Regulatory timeline

Built from our lineage records — each fact carries its provenance; missing history simply is not shown (never guessed).

What is the difference between the three FATF groups in this circular?

Group 1 (Iran) requires members to apply countermeasures to protect the financial system. Group 2 (Angola, DPRK, Ecuador, Ethiopia) have deficiencies but no action plan committed, so members must consider risks. Group 3 (Pakistan, Turkmenistan, Sao Tome and Principe) have previously identified deficiencies that remain unaddressed.

Do we need to stop all transactions with these countries?

No, but you must apply risk-based measures. For Iran, countermeasures are called for; for others, enhanced due diligence and risk assessment are required. The circular does not mandate a blanket ban.

How does this circular affect our existing KYC/AML procedures?

It requires you to update your risk assessment to incorporate these specific jurisdictions and adjust transaction monitoring, customer due diligence, and reporting processes accordingly.

📜 This document’s life story (1 recorded event, each backed by RBI’s own words)
Repealed by RBI/2025-26/100 — Consolidation of Regulations — Withdrawal of circulars (28 Nov 2025)
RBI’s words: “Official withdrawal register entry #1741: DBOD.AML.No.16477/14.01.034/2009-10 — "Know Your Customer (KYC) Norms / Anti-Money Laundering (AML) Standards / Combating of Financing of Terrorism (CFT)" dat”
📜 Read the original circular — full text as issued by RBI
RBI/2009-10/361 DBOD. AML.No.16477/14.01.034/2009-10 March 26, 2010 The Chairmen/CEOs of all Scheduled Commercial Banks(Excluding RRBs)/ Local Area Banks / All India Financial Institutions Dear Sir, Know Your Customer (KYC) Norms/ Anti- Money Laundering (AML) Standards/ Combating of Financing of Terrorism (CFT) Please refer to our letter DBOD. AML.No.8923 /14.01.032/2009-10 dated November 20, 2009 on risks arising from the deficiencies in AML/CFT regime of Iran, Uzbekistan, Pakistan, Turkmenistan and Sao Tome and Principe. 2. Financial Action Task Force (FATF) has issued a further Statement on February 18, 2010 on the subject ( copy enclosed ). It may be observed that the instant FATF statement divides the strategic AML/CFT deficient jurisdictions into three groups as under: Jurisdictions subject to FATF call on its members and other jurisdictions to apply countermeasures to protect the international financial system from the ongoing and substantial money laundering and terrorist financing (ML/FT) risks emanating from the jurisdiction: Iran Jurisdictions with strategic AML/CFT deficiencies that have not committed to an action plan developed with the FATF to address key deficiencies as of February 2010. The FATF calls on its members to consider the risks arising from the deficiencies associated with each jurisdiction: Angola , Democratic People's Republic of Korea (DPRK), Ecuador and Ethiopia. Jurisdictions previously publicly identified  by the FATF as having strategic AML/ CFT  deficiencies, which remain to be addressed as of February 2010: Pakistan, Turkmenistan and Sao Tome and Principe. 3. All banks and All India Financial Institutions are accordingly advised to take into account risks arising from the deficiencies in AML/CFT regime of these countries. 4 . Please advise Principal Officer of your bank to acknowledge receipt of this circular letter. Yours faithfully, (Vinay Baijal) Chief General Manager Encl: As above
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2009-10/361 · issued 26 Mar 2010. The plain-English explanation above is BankPulse’s own independent summary.
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Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=5547&Mode=0 — Plain-English summary by BankPulse (bankpulse.ai), reviewed by our expert reviewer, CA Amit Jain. Independent platform, not affiliated with the Reserve Bank of India; is our own plain-English paraphrase, not RBI’s original wording.
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