Money Laundering Regulation Update & Templates

Policy checklist clipboardSince Brexit, many of the UK’s regulations and legislation have required amendments to ensure they fit within the UK’s legal framework and not that of the EU. On 26th March 2021, the Money Laundering and Terrorist Financing (Amendment) (High-Risk Countries) Regulations came into force which provided the UK with its own list of high-risk countries.

The UK previously referred to high-risk countries as those identified by the European Commission, however the new Statutory Notice amended the MLR17 to give the UK its own list of countries where enhanced due diligence is required under the Money Laundering Regulations.

The UK remains a committed member of FATF and also utilises their guidance and list of countries that are high-risk and other monitored jurisdictions. This provides additional security when completing enhanced due diligence and carrying out analysis.

The Money Laundering and Terrorist Financing (Amendment) (High-Risk Countries) Regulations 2021 are referred to in the MLR17 under the obligation to apply enhanced customer due diligence and denote a high-risk third country as those specified in Schedule 3ZA of the instrument.

The current list of high-risk third countries in Schedule 3ZA are: –

  • 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