AML – High Risk Third Countries

27 October, 2025

With effect from 24th October 2025, there have been a some changes to the countries which are on the international Financial Action Task Force (FATF) “grey list” (those subject to increased monitoring):

• Burkina Faso, Mozambique, Nigeria and South Africa were removed from the grey list.
• No countries were added to the grey list.

Bear in mind that the UK list of high risk third countries (HRTC) now mirrors the FATF lists so CLC practices need to ensure that Enhanced Due Diligence (EDD) is applied when a client is “established” in a HRTC which means for an individual being resident in that country (not just having been born there) and for a company/legal person that means being incorporated in or having its principal place of business in that country.

The EDD that must be carried out is very specific under the 2017 Regulations and includes: obtaining additional information on the customer and on the customer’s beneficial owner, obtaining additional information on the intended nature of the business relationship, obtaining the approval of senior management for establishing and continuing the business relationship, conducting enhanced monitoring of the business relationship and others under Regulation 33(3A)(a) – (f).

Use the CLC’s AML Toolkit