On November 12, HM Treasury published an advisory note on money laundering and terrorist financing controls in jurisdictions outside the European Union. The advisory note identifies that on October 23, the Financial Action Task Force (FATF) published two statements identifying those jurisdictions that the FATF deems to have “strategic deficiencies” in their anti-money laundering and counter terrorist financing regimes. The HM Treasury advisory note may be seen as an explicit acknowledgement of and support for the FATF’s statements.

The United Kingdom’s Money Laundering Regulations 2007 require regulated entities to have policies and procedures in place so as to prevent activities related to money laundering and terrorist financing. Consequently, the HM Treasury advisory note advises firms to:

  • consider North Korea, Iran and Myanmar high risks for the purposes of the Money Laundering Regulations 2007, and to apply enhanced due diligence measures in accordance with the risks; and
  • take appropriate actions in relation to Afghanistan, Algeria, Angola, Bosnia and Herzegovina, Guyana, Iraq, Laos, Panama, Papua New Guinea, Syria, Uganda and Yemen to minimize the associated risks, possibly applying enhanced due diligence measures in high-risk situations.

The FATF statements are available here.

HM Treasury’s advisory notice is available here.

For details on the specific sanctions in place against the countries referenced above, please see HM Treasury’s regime specific lists here.