The document is a report on Cuba's anti-money laundering and counter-terrorist financing measures based on a mutual evaluation. It provides ratings on Cuba's effectiveness and technical compliance in various areas. For effectiveness, Cuba was rated as moderate for most objectives except being substantial for legal persons/arrangements and proceeds of crime. For technical compliance, Cuba was rated as compliant or largely compliant for most recommendations except being partially compliant for non-profit organizations, regulation of DNFBPs, powers of authorities, and sanctions.

1. Anti-money laundering and counter-terrorist financing measures in Cuba – Mutual Evaluation Report – July 2015 1
Anti-money laundering and counter-
terrorist financing (AML/CTF)
measures in Cuba
Mutual Evaluation
Ratings
July 2015
www.fatf-gafi.org/publications/mutualevaluations/documents/mer-cuba-2015.html

2. Anti-money laundering and counter-terrorist financing measures in Cuba – Mutual Evaluation Report – July 2015
Ratings – Effectiveness (1/3)
2
Extent to which Cuba
has achieved this
objective
1 ML and TF risks are understood and, where appropriate,
actions co-ordinated domestically to combat ML and TF
Moderate
2 International co-operation delivers appropriate
information, financial intelligence, and evidence, and
facilitates action against criminals and their assets
Moderate
3 Supervisors appropriately supervise, monitor and regulate
financial institutions and designated non-financial
businesses and professions (DNFBPs) for compliance with
AML/CFT requirements commensurate with their risks.
Substantial
4 Financial institutions and DNFBPs adequately apply
AML/CFT preventive measures commensurate with their
risks, and report suspicious transactions.
Moderate
Immediate outcome of an effective system to combat money
laundering (ML) and terrorist financing (TF)

3. Anti-money laundering and counter-terrorist financing measures in Cuba – Mutual Evaluation Report – July 2015
Ratings – Effectiveness (2/3)
3
Extent to which Cuba
has achieved this
objective
5 Legal persons and arrangements are prevented from misuse
for money laundering or terrorist financing, and
information on their beneficial ownership is available to
competent authorities without impediments.
Substantial
6 Financial intelligence and all other relevant information are
appropriately used by competent authorities for money
laundering and terrorist financing investigations.
Moderate
7 Money laundering offences and activities are investigated
and offenders are prosecuted and subject to effective,
proportionate and dissuasive sanctions.
Moderate
8 Proceeds and instrumentalities of crime are confiscated. Substantial
Immediate outcome of an effective system to combat money
laundering (ML) and terrorist financing (TF)

4. Anti-money laundering and counter-terrorist financing measures in Cuba – Mutual Evaluation Report – July 2015
Ratings – Effectiveness (3/3)
4
Extent to which Cuba
has achieved this
objective
9 Terrorist financing offences and activities are investigated
and persons who finance terrorism are prosecuted and
subject to effective, proportionate and dissuasive
sanctions.
Substantial
10 Terrorists, terrorist organisations and terrorist financiers
are prevented from raising, moving and using funds, and
from abusing the non-profit sector.
Substantial
11 Persons and entities involved in the proliferation of
weapons of mass destruction are prevented from raising,
moving and using funds, consistent with the relevant
United Nations Security Council Resolutions.
Moderate
Immediate outcome of an effective system to combat money
laundering (ML) and terrorist financing (TF)

5. Anti-money laundering and counter-terrorist financing measures in Cuba – Mutual Evaluation Report – July 2015
Ratings – Effectiveness
5
0
5
6
0
High
Substantial
Moderate
Low

6. Anti-money laundering and counter-terrorist financing measures in Cuba – Mutual Evaluation Report – July 2015
Ratings – technical compliance (1/5)
18-Dec-15
6
AML/CFT POLICIES AND COORDINATION
1. Assessing risks & applying a risk-based approach LaLaLaLa Largely compliant
2. National cooperation and coordination CCCC Compliant
MONEY LAUNDERING AND CONFISCATION
3. Money laundering offence LaLaLaLa Largely compliant
4. Confiscation and provisional measures LaLaLaLa Largely compliant
TERRORIST FINANCING AND FINANCING OF PROLIFERATION
5. Terrorist financing offence CCCC Compliant
6. Targeted financial sanctions related to terrorism & terrorist financing CCCC Compliant
7. Targeted financial sanctions related to proliferation LaLaLaLa Largely compliant
8. Non-profit organisations P P P P Partially compliant

7. Anti-money laundering and counter-terrorist financing measures in Cuba – Mutual Evaluation Report – July 2015
Ratings – technical compliance (2/5)
18-Dec-15
7
PREVENTIVE MEASURES
9. Financial institution secrecy laws CCCC Compliant
Customer due diligence and record keeping
10. Customer due diligence LaLaLaLa Largely compliant
11. Record keeping CCCC Compliant
Additional measures for specific customers and activities
12. Politically exposed persons CCCC Compliant
13. Correspondent banking CCCC Compliant
14. Money or value transfer services LaLaLaLa Largely compliant
15. New technologies CCCC Compliant
16. Wire transfers CCCC Compliant

8. Anti-money laundering and counter-terrorist financing measures in Cuba – Mutual Evaluation Report – July 2015
Ratings – technical compliance (3/5)
18-Dec-15
8
PREVENTIVE MEASURES (continued)
Reliance, Controls and Financial Groups
17. Reliance on third parties CCCC Compliant
18. Internal controls and foreign branches and subsidiaries CCCC Compliant
19. Higher-risk countries CCCC Compliant
Reporting of suspicious transactions
20. Reporting of suspicious transactions CCCC Compliant
21. Tipping-off and confidentiality CCCC Compliant
Designated non-financial Businesses and Professions (DNFBPs)
22. DNFBPs: Customer due diligence LaLaLaLa Largely compliant
23. DNFBPs: Other measures LaLaLaLa Largely compliant

9. Anti-money laundering and counter-terrorist financing measures in Cuba – Mutual Evaluation Report – July 2015
Ratings – technical compliance (4/5)
18-Dec-15
9
24. Transparency and beneficial ownership of legal persons LaLaLaLa Largely compliant
25. Transparency and beneficial ownership of legal arrangements CCCC Compliant
Regulation and Supervision
26. Regulation and supervision of financial institutions LaLaLaLa Largely compliant
27. Powers of supervisors LaLaLaLa Largely compliant
28. Regulation and supervision of DNFBPs P P P P Partially compliant
Operational and Law Enforcement
29. Financial intelligence units LaLaLaLa Largely compliant
30. Responsibilities of law enforcement and investigative authorities LaLaLaLa Largely compliant
31. Powers of law enforcement and investigative authorities P P P P Partially compliant
32. Cash couriers CCCC Compliant
TRANSPARENCY AND BENEFICIAL OWNERSHIP OF LEGAL PERSONS AND ARRANGEMENTS
POWERS AND RESPONSIBILITIES OF COMPETENT AUTHORITIES AND OTHER INSTITUTIONAL
MEASURES

10. Anti-money laundering and counter-terrorist financing measures in Cuba – Mutual Evaluation Report – July 2015
Ratings – technical compliance (5/5)
18-Dec-15
10
General Requirements
33. Statistics LaLaLaLa Largely compliant
34. Guidance and feedback LaLaLaLa Largely compliant
Sanctions
35. Sanctions P P P P Partially compliant
INTERNATIONAL COOPERATION
36. International instruments LaLaLaLa Largely compliant
37. Mutual legal assistance LaLaLaLa Largely compliant
38. Mutual legal assistance: freezing and confiscation LaLaLaLa Largely compliant
39. Extradition LaLaLaLa Largely compliant
40. Other forms of international cooperation LaLaLaLa Largely compliant
POWERS AND RESPONSIBILITIES OF COMPETENT AUTHORITIES AND OTHER INSTITUTIONAL
MEASURES (continued)

11. Anti-money laundering and counter-terrorist financing measures in Cuba – Mutual Evaluation Report – July 2015
Ratings – technical compliance
11
16
20
4 0
Compliant
Largely compliant
Partially compliant
Non compliant