High-risk third countries for AML purposes

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

Until the end of the Brexit transition period, the list of high-risk countries was determined by the EU under the 4th Anti Money Laundering Directive.

From 1 January 2021, the UK has had its own standalone list. Since then, any amendments made by the European Union to their 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 and has announced proposals to align further with Financial Action Task Force (FATF) practices.

The aim remains tackling strategic deficiencies in the identified countries with regards to their national anti-money laundering (AML) 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.

High-risk third countries

The current 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 was amended by regulation 2 of the Money Laundering and Terrorist Financing (Amendment) (High-Risk Countries) Regulations 2021).

The high-risk third countries are:

  • Albania
  • Barbados
  • Botswana
  • Burkina Faso
  • Cambodia
  • Cayman Islands
  • Democratic People's Republic of Korea (DPRK) 
  • Ghana
  • Iran
  • Jamaica
  • Mauritius
  • Morocco
  • Myanmar
  • Nicaragua
  • Pakistan
  • Panama
  • Senegal
  • Syria
  • Uganda
  • Yemen
  • Zimbabwe

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

The list was later amended in four delegate regulations:

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