We have an incoming wire from the Phillipines and it hit our OFAC tracker as a "non-cooperative country ncct.cdf." What does this mean - can we accept the wire?

The Financial Action Task Force (FATF) is an international organization dedicated to the prevention of money laundering around the globe. Non-Cooperative Countries or Territories (NCCT) are those jurisdictions identified by the FATF as non-cooperative in this fight. The FATF evaluates jurisdictions on an annual basis and adds or deletes from the list as appropriate.

Common characteristics of NCCTs are:

Strict banking secrecy laws which prevent access to relevant information for administrative and investigative purposes
Questionable or nonexistent requirements for identifying true account owners
Limited punishment for persons convicted of money laundering
Very limited or no regulatory oversight to ensure illegal activities do not occur
No mechanism for reporting suspicious activities
Special attention will be given to business relationships and transactions with persons, companies, and financial institutions associated with NCCTs. Such transactions having no apparent economic or lawful purpose will receive enhanced scrutiny and a SAR filed where applicable. All persons in a position to witness transactions or customers associated with NCCTs will be responsible for notifying the BSA Officer of those appearing suspicious. These persons include but are not limited to Consumer, Commercial and International Department personnel.

Non-Cooperative Countries or Territories
as of April 6, 2004.

1. Cook Islands
2. Guatemala
3. Indonesia
4. Myanmar
5. Nauru
6. Nigeria
7. Philippines