The latest Financial Action Task Force (FATF) plenary took place on the 24 October 2025.
As a reminder, Enhanced Due Diligence as prescribed by the Money Laundering Regulations is required where clients (and other parties) are established in a high-risk third country (HRTC). The UK’s HRTC list mirrors the FATF list 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) with established in the new countries added as EDD will now be required on those. You may also wish to consider EDD where your clients (or other parties connected with the matter) have connections with those countries.
Burkina Faso, Mozambique, Nigeria and South Africa have all been removed from the list. Remember, the FATF black list countries (which are considered highest risk) are North Korea, Iran and Myanmar.
The full list now includes the following countries:
- Algeria
- Angola
- Bolivia
- British Virgin Islands (BVI)
- Bulgaria
- Cameroon
- Cote d’Ivoire
- DPRK (North Korea)
- Democratic republic of the Congo
- Haiti
- Iran
- Kenya
- Lao PDR (Laos)
- Lebanon
- Monaco
- Myanmar
- Namibia
- Nepal
- South Sudan
- Syria
- Venezuela
- Vietnam
- Yemen
It is also worth remembering that just because a country is removed from the FATF list, it does not mean it is suddenly low risk, just that it is not as high as it was! Enhanced Due Diligence may still be required when dealing with a client established in, or with connections to, such a country. It is also sensible to consider countries that rank poorly on the Transparency International corruption perceptions index.
Please reach out if you have any questions.