High-risk third countries for AML purposes

High-risk third countries

The latest amendments to the FATF lists came into force on 21 February 2025.

Lao PDR and Nepal were added to the FATF lists and the Philippines was removed.

The European Council published the EU list of non-cooperative jurisdictions for tax purposes on 8 October 2024.

The high-risk third countries are:

• Algeria
• Angola
• Bulgaria
• Burkina Faso
• Cameroon
• Côte d'Ivoire
• Croatia
• Democratic People's Republic of Korea (DPRK)*
• Democratic Republic of the Congo*
• Haiti*
• Iran*
• Kenya
• Lao PDR
• Lebanon
• Mali*
• Monaco
• Mozambique
• Myanmar*
• Namibia
• Nepal
• Nigeria
• Senegal***
• South Africa
• South Sudan*
• Syria* **
• Tanzania
• Venezuela
• Vietnam
• Yemen* **

*These jurisdictions are subject to financial sanctions measures, which require firms to take additional measures.

**The FATF was unable to conduct an onsite visit due to security issues.

***Removed from the FATF lists but still on the EU list.

From 22 January 2024, HM Treasury amended the definition of ‘high-risk third countries’.

Regulation 33(3)(a) of the Money Laundering Regulations 2017 defines a high-risk third country as:

“a country named on either of the following lists published by the Financial Action Task Force as they have effect from time to time

1. high-risk jurisdictions subject to a call for action
2. jurisdictions under increased monitoring”

These lists are updated three times a year, on the final day of each FATF plenary meeting, held every February, June and October.

See the lists on the FATF website

See the EU list on the European Council website

The dates of these meetings are published several months in advance in the FATF event calendar.

All countries included in FATF's lists have significant shortcomings in their AML, counter-terrorist financing and counter-proliferation financing controls.

HM Treasury also published an updated advisory notice on high-risk third countries.

Background

Under the UK’s AML regime (regulation 33(1)(b)), any business relationship with a person established in a high-risk third country must be subject to enhanced due diligence (EDD).

Until the end of the Brexit transition period, the list of high-risk countries was determined by the European Union (EU).

From 1 January 2021, the UK has had its own standalone list. Since then, any amendments to the EU 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. 

The aim remains tackling strategic deficiencies in the identified countries with regards to their national 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.