On 29th March 2021, The Money Laundering and Terrorist Financing (Amendment) (High-Risk Countries) Regulations 2021 introduced a new UK list of high-risk third countries for enhanced customer due diligence requirements. The list includes the following countries: Albania, Barbados, Botswana, Burkina Faso, Cambodia, Cayman Islands, Democratic People’s Republic of Korea, Ghana, Iran, Jamaica, Mauritius, Morocco, Myanmar, Nicaragua, Pakistan, Panama, Senegal, Syria, Uganda, Yemen, Zimbabwe”.
Any references to high-risk third countries within the Guidance are therefore to be interpreted accordingly.
Impact on relevant organisations
Applicable institutions are required to apply enhanced due diligence (EDD) measures in any transaction or business relationship with a person established in a high-risk third country. This includes any transaction or business relationship involving:
- A person who is established in a high-risk third country.
- Politically exposed persons (PEP), their family member of a PEP or known associate of a PEP.
- Any situation presenting a higher risk of money laundering or terrorist financing.
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