High-risk third countries tracker
High-risk third countries tracker

The following Practice Compliance guidance 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.


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:

  1. FATF Public Statement—October 2019

  2. FATF: Improving Global AML/CTF Compliance: on-going process, 18 October 2019

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 measures and enhanced ongoing monitoring in any transaction or business relationship with a person established in a high-risk thi