High-risk third countries for AML purposes

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13 Jun 2023
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The list of high-risk countries is set out in schedule 3ZA of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.

The list until recently mirrored the Financial Action Task Force's (FATF) jurisdictions under increased monitoring and high-risk jurisdictions subject to a call for action. Schedule 3ZA consolidated these lists into a single list of countries, as all countries included in either of the FATF's lists have significant shortcomings in their anti-money laundering, counter-terrorist financing and counter-proliferation financing controls.

The FATF lists were updated in February 2023 and the UK has not yet updated Schedule 3ZA accordingly.

The additional countries which the FATF identifies as jurisdictions under increasing monitoring, but which are not yet on the UK list, are Nigeria and South Africa.

The high-risk third countries are:

  • Albania
  • Barbados
  • Burkina Faso
  • Cayman Islands
  • Democratic People's Republic of Korea (DPRK)*
  • Democratic Republic of the Congo
  • Gibraltar
  • Haiti
  • Iran*
  • Jamaica
  • Jordan
  • Mali*
  • Mozambique
  • Myanmar*
  • Panama
  • Philippines
  • Senegal
  • South Sudan*
  • Syria*
  • Tanzania
  • Turkey
  • Uganda
  • United Arab Emirates
  • Yemen*

*The Democratic Republic of the Congo, Gibraltar, Mozambique and Tanzania have been added to the list and Malta, Nicaragua and Pakistan have been removed.

*These jurisdictions are subject to financial sanctions measures, which require firms to take additional measures.

On 14 November 2022, HM Treasury published an advisory notice on high-risk third countries.

Background

Under the UK’s Money Laundering Regulations (regulation 33(1)(b)), any business relationship with a person established in a high-risk third country must be subject to enhanced due diligence (EDD).

Until the end of the Brexit transition period, the list of high-risk countries was determined by the European Union (EU).

From 1 January 2021, the UK has had its own standalone list. Since then, any amendments to the EU list do not have effect in the UK.

The UK is entitled to amend its own list of high-risk countries under section 49 of the Sanctions and Anti Money Laundering Act 2018.

The 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.

Schedule 3ZA consolidates these lists into a single list of countries, as all countries included in either of the FATF's lists have significant shortcomings in their anti-money laundering, counter-terrorist financing and counter-proliferation financing controls.

The aim remains tackling strategic deficiencies in the identified countries with regards to their national anti-money laundering and counter-financing of terrorism regimes.

You must apply 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 anti-money laundering guidance for the legal sector.

Previous amendments

View the EC's original list of high-risk third countries (July 2016)

The list was later amended in four delegate regulations:

Since the end of the Brexit transition period, the list has been amended in:

Find out more

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