FATF Plenary

Both the Black List and the Grey List are regarded as High Risk Third Countries to which Enhanced Due Diligence applies.

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. 

FATF Black List Grey List

HM Treasury update 

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

Regulation 33(3) of MLRs

Legal Sector Affinity Group Guidance - 23 April 2025

- Update your Firm Wide Risk Assessment?

- Update your Client Matter Risk Assessment?

- Update the information requests you seek from your prospective clients?

- Update the information you are seek from your existing clients?

- 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 documents?

- Update your training?

- Document and record your actions?

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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