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AML – HM Treasury publishes new list of high risk third countries
7 July 2022

HM Treasury has published a new statutory instrument coming into force on 11th July 2022 which will substitute 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’). This 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. Following its most recent review, the FATF now also identifies Gibraltar as high-risk. Following improvements in its AML regime, Malta is no longer subject to the FATF’s increased monitoring process.

On 17 June 2022 the FATF published two statements identifying jurisdictions with strategic deficiencies in their AML/CTF regimes. In response to the latest FATF statements, HM Treasury advises firms to consider the following:

The following jurisdictions will be included in Schedule 3ZA of the MLRs:


Albania
Barbados
Burkina Faso
Cambodia
Cayman Islands
DPRK*
Gibraltar
Haiti
Iran*
Jamaica
Jordan
Mali*
Morocco
Myanmar*
Nicaragua*
Pakistan
Panama
Philippines
Senegal
South Sudan*
Syria*
Türkiye
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 here.

On 17 June 2022 the FATF also published a separate statement on the Russia Federation. The statement includes the following requests that firms may wish to be aware of: “the FATF continues to call upon all jurisdictions to remain vigilant of threats to the integrity, safety and security of the international financial system arising from the Russian Federation’s aggression in Ukraine. The FATF reiterates that all jurisdictions should be vigilant to possible emerging risks from the circumvention of measures taken in order to protect the international financial system.”

To read the HM Advisory Notice in full, click here.

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