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AML: HM Treasury updates list of high-risk third countries
26 June 2023

HM Treasury has published a new statutory instrument coming into force tomorrow (27th June 2023). This substitutes the list of high risk third countries specified in schedule 3ZA of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the ‘MLRs’). The list continues to mirror both the Financial Action Task Force’s (FATF) ‘Jurisdictions under increased monitoring’ and ‘High-risk jurisdictions subject to a call for action’ documents. High-risk jurisdictions’ anti-money laundering, anti-terrorism funding, and anti-proliferation financing regimes have significant strategic deficiencies.

Under the MLRs (regulation 33(1)(b)) any business relationship with a person established in a high-risk third country must be subject to enhanced due diligence (EDD).

The update removes Cambodia and Morocco from the list.

As of 27th June 2023, the high-risk third countries are:

  • Albania
  • Barbados
  • Burkina Faso
  • Cayman Islands
  • Democratic Republic of the Congo*
  • Democratic People’s Republic of Korea (DPRK)*
  • Gibraltar
  • Haiti
  • Iran*
  • Jamaica
  • Jordan
  • Mali*
  • Mozambique
  • Myanmar*
  • Panama
  • Philippines
  • Senegal
  • South Sudan*
  • Syria*
  • Tanzania
  • Turkey
  • Uganda
  • United Arab Emirates
  • Yemen*

*These jurisdictions are subject to financial sanctions measures at the time of publication of this notice which require firms to take additional measures. Details can be found on the Financial sanctions targets by regime collection page

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