High-risk third countries tracker

The following Practice Compliance practice note provides comprehensive and up to date legal information covering:

  • High-risk third countries tracker
  • FATF
  • UK
  • High-risk third countries
  • Countries subject to sanctions

High-risk third countries tracker

Organisations caught by the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692 must:

  1. apply enhanced customer due diligence (CDD) measures and enhanced ongoing monitoring in any transaction or business relationship with a person established in a high-risk third country

  2. not rely on a third party established in a high-risk third country

The requirement to apply enhanced due diligence for high-risk third countries applies where there is a relevant transaction and establishment in a high-risk third country. A relevant transaction is a transaction in relation to which you are required to apply CDD measures under MLR 2017, reg 27 and being established in a country means:

  1. in the case of a legal person, being incorporated in or having its principal place of business in that country, or, in the case of a financial institution or a credit institution, having its principal regulatory authority in that country, and

  2. in the case of an individual, being resident in that country, but not merely having been born in that country

This Practice Note lists high-risk third countries identified by the Financial

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