HMT Advisory Notice - High Risk Third Countries Update - January 2024

HM Treasury have amended their definition of High Risk Third Countries (HRTC). The amendment to The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the MLRs) removes references to schedule 3Za and defines a HRTC under regulation 33(3)(a) as:

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

(i) High-Risk Jurisdictions subject to a Call for Action;

(ii) Jurisdictions under Increased Monitoring”

Members should now refer directly to the FATF website here to view the lists. No additional countries have come into scope through this update; however, members should be aware that these lists are updated in February, June and October each year.

Members are reminded that they must carry out enhanced due diligence and enhanced ongoing monitoring in any business relationship with a person established in a high-risk third country or in relation to any relevant transaction where either of the parties to the transaction is established in a high-risk third country. These lists include jurisdictions that are subject to financial sanctions measures which require firms to take additional measures.

An advisory notice on high risk third countries to explain the changes and clarify firms’ obligations is available on gov.uk here. 

Supervised firms with queries about the requirements should contact the Professional Standards team by email [email protected].