On 25 October 2018, HM Treasury updated its advisory notice on money laundering and terrorist financing controls in higher risk jurisdictions. The advisory notice briefly sets out the requirement to apply Enhanced Due Diligence for higher risk jurisdictions and attaches two statements that the Financial Action Task Force (FATF) published on 19 October 2018 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 enhanced due diligence (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, Ethiopia, Ghana, Pakistan, Serbia, Sri Lanka, Syria, Trinidad and Tobago, Tunisia and Yemen.