Updated SRA Guidance on High-Risk Third Countries

Historically, HRTCs were defined by the European Union. Following Brexit, the UK adopted its own list under Schedule 3ZA of the Money Laundering Regulations 2017 (MLR 2017). This changed on 22 January 2024, when the definition was updated to align with the Financial Action Task Force (FATF) lists:

• High-risk jurisdictions subject to a call for action
• Jurisdictions under increased monitoring

These lists are updated every February, June, and October, and firms must apply enhanced due diligence (EDD) under Regulation 33 when dealing with clients established in these jurisdictions.

Why Historic Designations Matter

A country’s removal from the high-risk list does not mean the risk disappears. Past designations often indicate structural weaknesses that criminals can exploit. For example:

• Lao PDR was high-risk from 2016 to 2020, removed, and then re-added in February 2025.
• This demonstrates that jurisdictions can fall back into non-compliance.

Firms should review historic client relationships and transactions involving previous HRTCs as part of ongoing monitoring under Regulation 28(11).

Find the full SRA guidance as of 4 December 2025 here.

Historic High-Risk Third Countries Table as of 4 December 2025 

Best Practice for Firms

To stay compliant and mitigate risk:

• Monitor transactions involving previous HRTCs
• Apply a risk-based approach to overseas transactions
• Update policies regularly in line with FATF changes