AML/CFT Country lists update – Immediate Action Required

The Authority wishes to draw your attention to a number of amendments to the various country lists following the March 2022 FATF Plenary and the most recent publication of the FATF’s consolidated table of 4th round assessment ratings. The country lists have been amended by the Cabinet Office and can be viewed on the DHA’s website.


If not already undertaken, regulated or supervised entities must carry out their own evaluation for any potential impact on their risk assessments and procedures, arising from the changes. The Authority reminds regulated and supervised entities that paragraph 15(7) of the AML/CFT Code lists matters which may pose a higher risk of ML/FT and includes “a business relationship or occasional transaction with a customer resident or located in a jurisdiction in List B’” (paragraph 15(7)(b)) and “activity in a jurisdiction in jurisdiction in List A or B” (paragraph 15(7)(c)). Regulated or supervised entities must review the country lists and make any necessary changes to business and customer risk assessments.


In particular the Authority would like to highlight that Russia has been placed on List B (“Jurisdictions that may pose a higher risk”) due to the FATF issuing a public statement on 3rd March 2022 concerning the ongoing situation in the Ukraine.


This means that, from the date of the list change, regulated or supervised entities can no longer use, or continue to rely on, simplified measures from the AML/CFT Code, such as the “Acceptable applicants” or “Eligible introducers” paragraphs, for new or existing customers or occasional transactions, where the “trusted person” or “external regulated person” is regulated or supervised in Russia.


It is requested that where simplified measures have been utilised for business relationships/customers connected to Russia, regulated or supervised entities should provide the Authority with the following details of those business relationships/customers:


  • The number of business relationships; and
  • Which simplified measures were used (including a breakdown of the numbers of business relationships each simplified measure was used for).


Additionally regulated and supervised persons should provide the Authority with details of the action they have taken, and confirm they have obtained full customer due diligence on effected business relationships/customers, or confirm they have taken action commensurate with paragraphs 8(5), 11(7) and 15(8)  of the AML/CFT Code if full CDD has not been obtained. These details should be provided to by the end of April 2022