On 26 February 2019, HM Treasury has published an updated advisory notice regarding the risks posed by unsatisfactory money laundering and terrorist financing controls in a number of jurisdictions.

The advisory notice briefly sets out the requirement to apply Enhanced Due Diligence (EDD) for higher risk jurisdictions and attaches as annexes the two statements that the Financial Action Task Force (FATF) issued on 22 February 2019 identifying jurisdictions with strategic deficiencies in their anti-money laundering / counter terrorist financing regimes.

In response to the latest FATF statements, HM Treasury advises firms to consider the following:

  • consider as high risk and apply counter measures and EDD measures in accordance with the risks: Democratic Peoples’ Republic of Korea;
  • consider as high risk and apply EDD measures in accordance with the risks: Iran; and
  • take appropriate actions to minimise the associated risks, which may include EDD measures in high risk situations: the Bahamas, Botswana, Cambodia, Ethiopia, Ghana, Pakistan, Serbia, Sri Lanka, Syria, Trinidad and Tobago, Tunisia and Yemen.