Dealing with FATF ‘at risk’ countries

IPA Insolvency Practitioner newsletter AML Digest, April 2026

HM Treasury have published their latest Money Laundering Notice, which can be found here. Nominated Officers for firms may want to add their names to the mailing list for financial services regulation to ensure that updates are provided to your firm to consider whether there is any impact on policies and procedures.

The latest notice looks at the changes outlined above to the FATF black and grey lists and the requirement to undertaken Enhanced Due Diligence (EDD) under Reg33 MLR17. The guidance confirms the position, that the IPA has advised members of previously, that an awareness of countries on the list is key and consideration of what EDD is required and steps to undertake further and ongoing due diligence is on a risk-based approach according to the circumstances of a particular appointment or transaction.

What will remain key for members is to ensure that where there may be an impact from a country on the FATF lists that there is a clear file note held of what EDD has been undertaken (or not undertaken on a risk-based approach) and what the conclusions reached are from that further EDD.