The Financial Action Task Force (FATF) has released its updated list of High-Risk Third Countries (HRTCs) as of 21 February 2025, identifying jurisdictions with strategic deficiencies in their AML/CFT frameworks. For small law firms, this update is a critical reminder to apply Enhanced Due Diligence (EDD) and ongoing monitoring when dealing with clients or transactions linked to these jurisdictions.
Why This Matters
Under Regulation 33(3)(a) of the Money Laundering Regulations, firms must apply EDD when engaging with individuals or entities established in countries listed by FATF under:
- Jurisdictions Under Increased Monitoring
- High-Risk Jurisdictions Subject to a Call for Action
EDD is not optional—it’s a legal requirement designed to mitigate the risk of money laundering and terrorist financing.
Updated HRTCs List (February 2025)
The following countries are currently listed:
- Algeria
- Angola
- Bulgaria
- Burkina Faso
- Cameroon
- Cote D’Ivoire
- Croatia
- Democratic People’s Republic of Korea (Sanctions)
- Democratic Republic of the Congo
- Haiti
- Iran (Sanctions)
- Kenya
- Lebanon
- Mali
- Monaco
- Mozambique
- Myanmar
- Namibia
- Nepal
- Nigeria
- People’s Democratic Republic of Lao
- Russian Federation*
- Senegal
- South Africa
- South Sudan
- Syria (Sanctions)
- Tanzania
- Venezuela
- Vietnam
- Yemen (Sanctions)
Countries in bold are subject to financial sanctions.
*Russia is independently flagged due to ongoing sanctions scrutiny following the 2022 invasion of Ukraine.
What Firms Should Do
- Apply EDD and enhanced monitoring for any client or transaction involving these jurisdictions.
- Do not assume safety if a country is not listed—risk assessments must be client-specific and risk-sensitive.
- Use tools like:
- FATF Jurisdictional Information
- Transparency International’s Corruption Index
- Basel AML Index
- CIA World Factbook
- Know Your Country
Final Tip: Review your firm’s AML policies and ensure your team is trained to identify and respond to high-risk jurisdictions. Staying informed is key to staying compliant.