The Financial Action Task Force (FATF) has updated its lists of high-risk countries again, following their latest plenary session which concluded on 13/2/26.
As a reminder, the Money Laundering Regulations 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. 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.
Kuwait and Papua New Guinea have been added to the list. No countries have been removed from the list this time.
The full list now includes the following countries (the three in bold are on the FATF ‘black’ list):
- Algeria
- Angola
- Bolivia
- British Virgin Islands (BVI)
- Bulgaria
- Cameroon
- Cote d’Ivoire
- DPRK (North Korea)
- Democratic republic of the Congo
- Haiti
- Iran
- Kenya
- Kuwait
- Lao PDR (Laos)
- Lebanon
- Monaco
- Myanmar
- Namibia
- 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), which has also recently been updated, is a useful tool to risk assess countries and consider whether EDD should be applied.