Following the Financial Action Task Force (FATF)’s latest plenary session, which concluded on Friday (19/6/26), the lists of high-risk countries have been updated again.
As a reminder, the Money Laundering Regulations (MLRs) (still currently) require that Enhanced Due Diligence (EDD) be carried out where clients (and other parties) are established in a high-risk third country (HRTC). The UK’s HRTC list mirrors the FATF lists so it is important to be aware of any changes to the FATF black and grey lists.
Although we are expecting amendments to the MLRs imminently which will mean that mandatory EDD will only be required in relation to ‘black list’ countries (namely North Korea, Iran and Myanmar), for the time-being it is business as usual. Make sure you update your policies, advise staff of the changes, and consider whether you are already acting for clients (or dealing with other parties) established in the new countries added, as EDD will now be required on those matters. You may also wish to consider EDD where your clients (or other parties connected with the matter) have connections with those countries.
Bosnia and Herzegovina and Iraq have been added to the list. Algeria and Namibia have been removed.
The full list now includes the following countries (the three in bold are on the FATF ‘black’ list):
- Angola
- Bolivia
- Bosnia and Herzegovina
- British Virgin Islands (BVI)
- Bulgaria
- Cameroon
- Cote d’Ivoire
- DPRK (North Korea)
- Democratic republic of the Congo
- Haiti
- Iran
- Iraq
- Kenya
- Kuwait
- Lao PDR (Laos)
- Lebanon
- Monaco
- Myanmar
- Nepal
- Papua New Guinea
- South Sudan
- Syria
- Venezuela
- Vietnam
- Yemen
Remember that these listed countries are not the only risky ones out there! Using the Transparency International corruption perceptions index (here) is a useful tool to risk assess countries and consider whether EDD should be applied.