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European Commission list of high risk third countries

Last updated: 19 March 2020

Article 9.2 of the Fourth EU Money Laundering Directive allows the European Commission to identify 'high-risk third countries'.

These countries are identified as having strategic deficiencies in their national anti-money laundering and counter-financing of terrorism regimes that pose significant threats to the EU’s financial system.

You must apply enhanced due diligence (EDD) measures in any transaction or business relationship with a person established in a high-risk third country.

For more guidance on appropriate EDD measures, see our guide to customer due diligence and the Legal Sector Affinity Group’s Anti-money laundering guidance.

High-risk third countries

Sixteen countries have been identified as high-risk third countries. They are:

  • Afghanistan
  • Bosnia and Herzegovina
  • Guyana
  • Iraq
  • Lao PDR
  • Syria
  • Uganda
  • Vanuatu
  • Yemen
  • Ethiopia
  • Sri Lanka
  • Trinidad and Tobago
  • Tunisia
  • Pakistan
  • Iran - seeking technical assistance in the implementation of the FATF Action Plan
  • Democratic People's Republic of Korea - has repeatedly failed to address deficiencies

View the European Commission’s original list of high-risk third countries (July 2016).

The list was later amended in three delegate regulations:

October 2017

December 2017

July 2018

The EU’s 5th Money Laundering Directive has broadened the criteria for the European Commission in assessing high-risk third countries. So it’s likely that this list will be expanded in future.

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