HM Treasury Money Laundering Advisory Notice

Shortly after the Financial Action Task Force (FATF) published their Black and Grey List, the Government released a Money Laundering Notice.

It seems that the notice informs UK regulated businesses ("relevant persons") about the updated lists of "High-Risk Third Countries" ("HRTCs") as identified by the Financial Action Task Force (FATF) and their obligations under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the "MLRs").

The primary purpose of this notice is to ensure that regulated entities apply enhanced customer due diligence (EDD) and enhanced ongoing monitoring to business relationships and transactions involving individuals and entities established in these HRTCs.

The first paragraph states:

'The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the “”) require the UK regulated sector to apply enhanced customer due diligence in relation to high-risk third countries (“”). This obligation is in addition to the requirement to apply enhanced customer due diligence where there is an assessed high risk of money laundering or terrorist financing, including geographic risk based on credible sources (for example the UK’s National Risk Assessment).'

the first paragraph of the notice clarifies that there are two distinct triggers for applying enhanced customer due diligence: 

1. when dealing with individuals or entities established in countries identified by the FATF as High-Risk Third Countries, and 
2. when there is a generally assessed high risk of money laundering or terrorist financing, which can include geographic risks identified through credible sources

HM Treasury - Money Laundering Advisory Notice February 2025 dated 27/03/2025

Financial Sanctions Targets by Regime 

This post is not legal or regulatory advice.