HM Treasury Updates High-Risk Third Countries List under Money Laundering Regulations

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A&O Shearman

HM Treasury has updated its money laundering advisory notice on high-risk third countries. Under the U.K. Money Laundering Regulations, the U.K. regulated sector must 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. High-risk third countries are those named by the Financial Action Task Force on either its "High-Risk Jurisdictions subject to a Call for Action" or "Jurisdictions under Increased Monitoring" lists. On October 25, 2024, the FATF published its most recent update to its lists of jurisdictions, which firms are advised to consider.

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