AML – Updated list of high risk third countries

Under the Money Laundering Regulations firms are required to apply enhanced due diligence on clients and transactions from countries identified by the European Commission as having a high risk of money laundering (“EU Commission High Risk Third Country List”).

From today (1st October 2020), the following countries have been added to this list: Bahamas, Barbados, Botswana, Cambodia, Ghana, Jamaica, Mauritius, Mongolia, Myanmar/Burma, Nicaragua, Panama and Zimbabwe.

The following countries were removed from the list on 9th July 2020: Bosnia-Herzegovina, Ethiopia, Guyana, Lao People’s Democratic Republic, Sri Lanka and Tunisia.

Given the regulatory focus on AML systems and controls, it is important to ensure that your firm’s AML policy is updated to reflect the new 2020 EU Commission High Risk Third Country List. Equally, the changes should also be reflected in your firm’s AML systems, processes and procedures when onboarding new clients and acting for existing ones. For example, the AML risk level you have historically assigned to a client may need to be revised.

The list of high risk third countries is now as follows:

  • Afghanistan
  • The Bahamas
  • Barbados
  • Botswana
  • Cambodia
  • Democratic People’s Republic of Korea
  • Ghana
  • Iran
  • Iraq
  • Jamaica
  • Mauritius
  • Mongolia
  • Myanmar
  • Nicaragua
  • Pakistan
  • Panama
  • Syria
  • Trinidad and Tobago
  • Uganda
  • Vanuatu
  • Yemen
  • Zimbabwe