Financial Action Task Force: Updates to black-list and grey-list jurisdictions
IPA Insolvency Practitioner newsletter, July 2024
Regulation 33(1)(b) of the Money Laundering Regulations 2017 (as amended) (MLR17) requires enhanced due diligence (EDD) to be carried out ‘in any business relationship with a person established in a high-risk third country on in relation to any relevant transaction where either of the parties to the transaction is established in a high-risk third country.’
Regulation 33(3)(a) advises that a high-risk third country means a country named on either of the following lists published by the Financial Action Task Force (FATF):
- High-Risk Jurisdictions subject to a Call for Action
- Jurisdictions under Increased Monitoring
FATF met on 28 June 2024 and have published amendments to the Jurisdictions under Increased Monitoring (the ‘grey list’). Monaco and Venezuela have been added to the list. Jamaica and Turkey have been removed from the list. The list is available on the FATF website.
There has been no change to the High-Risk Jurisdictions which remain North Korea, Iran & Myanmar. The list of High-Risk Jurisdictions is available here.
If you are carrying out due diligence work and you receive information that indicates a link to a country on the black-list or grey-list, please ensure that the position is flagged on the case risk assessment and consideration made as to whether there are any ongoing dealings or funding from the relevant jurisdictions which may indicate a higher AML risk.