On 28 October 2021, HM Treasury (HMT) published its latest advisory notice concerning money laundering and terrorist financing controls in higher risk jurisdictions. The advisory notice follows two statements that the Financial Action Task Force (FATF) published on 21 October 2021 identifying jurisdictions with strategic deficiencies in their anti-money laundering / counter terrorist financing regimes.

In response to the latest FATF statements, HMT sets out a list of jurisdictions that it considers as high risk where firms should apply counter measures and enhanced due diligence measures: DPRK and Iran. HMT also sets out a list of jurisdictions where firms should take appropriate action to minimise the associated risks, which may include enhanced due diligence measures in high risk situations: Albania, Barbados, Burkina Faso, Cambodia, Cayman Islands, Haiti, Jamaica, Jordan, Mali, Malta, Morocco, Myanmar, Nicaragua, Pakistan, Panama, Philippines, Senegal, South Sudan, Syria, Turkey, Uganda, Yemen, Zimbabwe (some of these jurisdictions are subject to financial sanctions measures which require firms to take additional measures, details can be found here).