On October 25, HM Treasury published an updated advisory notice on money laundering and terrorist financing controls in higher risk jurisdictions.
The Money Laundering, Terrorist Financing and Transfer of Funds (Information of the Payer) Regulations 2017 require firms to implement policies and procedures to prevent activities relating to money laundering and terrorist financing.
On October 19, the Financial Action Task Force (FATF) published two statements (found in Annex A and Annex B of the advisory notice) identifying jurisdictions with strategic deficiencies in their anti-money laundering and counter-terrorism financing regimes. In response to FATF’s statements, HM Treasury suggests that firms note the following:
- Consider the Democratic People’s Republic of Korea (North Korea) as a high-risk jurisdiction, and apply countermeasures and enhanced due diligence measures in accordance with the associated risks;
- Consider Iran as high risk and apply enhanced due diligence measures in accordance with the associated risks;
- Take appropriate actions, such as enhanced due diligence in high-risk situations, to minimize associated risks relating to the Bahamas, Botswana, Ethiopia, Ghana, Pakistan, Serbia, Sri Lanka, Syria, Trinidad and Tobago, Tunisia, and Yemen.
Additionally, at the time of the advisory notice’s publication, North Korea, Iran, Syria, Tunisia and Yemen are subject to financial sanctions which require firms to take additional measures.
The advisory notice is available here.
Details of the financial sanctions to be taken by firms in relation to specific, high-risk jurisdictions are available here.