FATF Plenary

The Financial Action Task Force (FATF) is a non-government body, that provides information and standards on Money Laundering, Terrorist Financing and Proliferation Financing.

The UK been a  member of FATF since 1990 and has adopted this lists commonly known as the Black List and the Grey List which state countries that require a call for action or increased monitoring. 

The countries stated are especially important because of their adoption under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations (MLRs). Regulation 33 sets out the obligation to apply enhanced due diligence. 

Refer to: 

Regulation 33(1)(b) 

Regulation 33(3)

LSAG 25 - 5.6.2 Geographic Risk

Countries Added To the Grey List:

• Bolivia

Countries Deleted From The Grey List

• Croatia 
• Mali
• United Republic of Tanzania

📢❗🚨In March 2025 the Treasury posted an update to February 2025 Guidance

It stated:

"Regulation 33(1)(b) of the  requires regulated businesses (“relevant persons”) to apply enhanced customer due diligence measures and enhanced ongoing monitoring in any business relationships with a person established in an  or in relation to any relevant transaction where either of the parties to the transaction is established in an . 

For these purposes, regulation 33(3) explains that:

An "HRTC" is defined 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—

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

(ii) Jurisdictions under Increased Monitoring”

Therefore the FATF Black and the Grey List are HRTC for the purpose of in-scope firms in the AML regime. 

You may wish to consider the update from Law Society of Scotland - Client Matter Risk Assessments.

Paragraph 6 of their guidance relates to Client Location, states that client location 'extends beyond sanctioned jurisdictions or those on so-called "international grey-lists". It also includes high-risk third countries.'

High Risk Third Countries (HRTC) 

HM Treasury released an Advisory notice which came into force on 22 January 2024, this note amended the definition of HRTC. 

It removes Schedule 3ZA containing the list of HRTCs in the MLRs. Instead of referring to a separate schedule, Regulation 33(3)(a) will now define an HRTC 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— 

1. High-Risk Jurisdictions subject to a Call for Action; 

2. Jurisdictions under Increased Monitoring 

In order to keep abreast of which countries are HRTCs, relevant persons will now have to refer directly to lists published by the Financial Action Task Force (‘FATF’) of ‘Jurisdictions Under Increased Monitoring’ and ‘High-Risk Jurisdictions subject to a Call for Action’. These lists are updated three times a year, on the final day of each FATF Plenary meeting, held every February, June and October.

Higher Risk jurisdictions 

You should note that there may be other jurisdictions that present a higher risk of money laundering that are not on the above FATF lists. 

LSAG section 5.6.2.1 provides further guidance on this. 

Further resources to help you consider whether a country is higher risk include: 

• AML and geographical risk| Law Society of Scotland (lawscot.org.uk)
• Transparency International's corruption perception index 
• The Basel AML Index  
• CIA World Factbook 
• International Narcotics Control Strategy Reports 
• FATF Jurisdictional Information 
• The Know Your Country rating table 

Please also see r.33(3) and sections 5.6.2.1, 5.6.2.3 & 6.19.1 of the LSAG guidance for further information and useful links which will assist you. 

Next Plenary: 24th October 2025

FATF holds 3 HRTC plenaries a year: 

💕February

🌞June, and 

🎃October.

FATF 

⚫Black List 

🔘Grey List

HM Treasury update 

Law Society of Scotland - Client Matter Risk Assessment Guidance April 2025

Regulation 33(1) of MLRs

Regulation 33(3) of MLRs

Legal Sector Affinity Group Guidance - 23 April 2025

LSAG 25 -  5.6.2. 

LSAG 25 - 6.19

⚙️Update your Firm Wide Risk Assessment - identify if you have expose to these geographical risks, assess the risks, and consider your mitigation

⚙️Update the Firm's List of High Risk Countries, and or prospect or client questionnaires

⚙️Update your Client Matter Risk Assessment - mark that you have considered the changes - decision making and outcome

⚙️ Amend where appropriate the prospect or client risk rating

⚙️ Apply EDD where appropriate, including source of funds and source of wealth

⚙️Update the information requests you seek from your prospective clients

⚙️Obtain updating information from your existing clients, checking existing clients for these new geographical risks

⚙️What about counterparties and third parties

⚙️Seek approval from MLRO/ Compliance Officer - for prospects and clients that now fall within HRTC

⚙️Update your High Risk Register

⚙️Seek approval from your board regarding updating core documents?

⚙️Update your training Plan, and your delivery

⚙️Document and record your actions

⚙️ Remember the update occurred Friday 13 June 2025 so you need to implement immediately

The information provided in this post is not legal or regulatory advice, and it is not intended that it is considered as such. 

Always make your own inquiries and seek independent legal and regulatory advice from a specialist advisor. 

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