High-risk third countries tracker
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
  • European Commission
  • HM Treasury
  • High-risk third countries
  • Countries subject to sanctions

This Practice Note lists high-risk third countries identified by the Financial Action Task Force (FATF), HM Treasury and the European Commission as having deficiencies in their anti-money laundering (AML) and counter-terrorist financing (CTF) regimes.

For further information, see Practice Note: Money Laundering Regulations 2017—enhanced due diligence—law firms.

FATF

The FATF identifies jurisdictions with weak measures to combat money laundering and terrorist financing in two FATF public documents that are issued three times a year, see FATF: High-risk and other monitored jurisdictions.

European Commission

The Commission maintains a list of third countries it has assessed under Article 9(2) of the Fourth Money Laundering Directive (EU) 2015/849 (4MLD).

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 regulation 27, MLR 2017, and being established in a country means:

  1. in the case of a legal person, being incorporated in

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