On 1 November 2021, there was published on the legislation.gov.uk website The Money Laundering and Terrorist Financing (Amendment) (No. 3) (High-Risk Countries) Regulations 2021 together with an explanatory memorandum. These Regulations amend the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 by substituting the list of high risk third countries in Schedule 3ZA for a new list. The new list mirrors the updates made by the Financial Action Task Force to its own list of high risk countries following its October Plenary.
The new Schedule 3ZA lists the following countries for the purposes of enhanced customer due diligence requirements: Albania, Barbados, Burkina Faso, Cambodia, Cayman Islands, Democratic People’s Republic of Korea, Haiti, Iran, Jamaica, Jordan, Mali, Malta, Morocco, Myanmar, Nicaragua, Pakistan, Panama, Philippines, Senegal, South Sudan, Syria, Turkey, Uganda, Yemen and Zimbabwe. Jordan, Mali and Turkey are newly defined as “high-risk third countries” as a result of the Regulations. Botswana and Mauritius no longer fall within this definition as a result of the Regulations.