HM Treasury have published new legislation following the recent FATF decision to add Turkey, Mali and Jordan to the list of high risk third countries. Under the UK’s Money Laundering Regulations (regulation 33(1)(b)), enhanced due diligence (EDD) is mandated for any business relationship with a person established in a high-risk third country.
The list of high-risk countries is set out in schedule 3ZA of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
Botswana and Mauritius are now longer subject to increased monitoring, whereas Turkey, Mali and Jordan have been added to the list. As of 2nd November, the following countries are to be treated as high risk:
1. Albania
2. Barbados
3. Burkina Faso
4. Cambodia
5. Cayman Islands
6. Democratic People’s Republic of Korea
7. Haiti
8. Iran
9. Jamaica
10. Jordan
11. Mali
12. Malta
13. Morocco
14. Myanmar
15. Nicaragua
16. Pakistan
17. Panama
18. Philippines
19. Senegal
20. South Sudan
21. Syria
22. Turkey
23. Uganda
24. Yemen
25. Zimbabwe
To ensure compliance with the regulations, firms should update their AML policies and risk assessments and ensure relevant staff are informed.
