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HM Treasury Advisory Notice: NEW High Risk Third Countries List!

Francesco Fulcoli - Chief Compliance Officer and MLRO

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 require the UK regulated sector to apply enhanced customer due diligence in relation to high-risk third countries.

Regulation 33(1)(b) of the MLRs requires regulated businesses to apply enhanced customer due diligence measures and enhanced ongoing monitoring in any business relationships with a person/entity established in a high-risk third country or in relation to any relevant transaction where either of the parties to the transaction is established in a high-risk third country.

Money Laundering and Terrorist Financing (High-Risk Countries) (Amendment) (No.2) Regulations 2023 will substitute the list of high-risk third countries specified in Schedule 3ZA of the MLRs with a new list that aligns with the FATF's lists of jurisdictions under increased monitoring and high-risk jurisdictions subject to a call for action.

Enhanced customer due diligence and enhanced ongoing monitoring should be applied to all person/entity, new and existing, established in high-risk third countries listed in schedule 3ZA.

Firms should consider the intensity and level of detail of the steps they take to meet their obligations under regulation 33(3A), taking a risk-based approach.

Group-wide controls require UK relevant firms to ensure that their branches or subsidiaries in high-risk third countries apply measures equivalent to enhanced customer due diligence measures set out in regulation 33(3A).

The update will add Bulgaria, Cameroon, Croatia, Nigeria, South Africa, and Vietnam, and remove HM Treasury Advisory Notice: High Risk Third Countries, Cayman Islands, Jordan, and Panama from Schedule 3ZA.

The new list of High Risk Third Countries:

  • Barbados, 
  • Bulgaria, 
  • Burkina Faso, 
  • Cameroon, 
  • Croatia, 
  • DPRK, 
  • Democratic Republic of the Congo, 
  • Gibraltar, 
  • Haiti, 
  • Iran, 
  • Jamaica, 
  • Mali, 
  • Mozambique, 
  • Myanmar, 
  • Nigeria, 
  • Philippines, 
  • Senegal, 
  • South Africa, 
  • South Sudan, 
  • Syria, 
  • Tanzania, 
  • Turkey, 
  • Uganda, 
  • United Arab Emirates, 
  • Vietnam, 
  • 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 targets by regime collection page.

This statutory instrument will come into force on 5 December 2023 and substitute the list of high-risk third countries specified in Schedule 3ZA of the MLRs with a new list.


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