AML: Changes to the list of high risk countries

24 February, 2025

The international Financial Action Task Force (FATF) met from 19 – 21 February 2025 and made changes to the countries which are on the “grey list” (those subject to increased monitoring):

• Laos and Nepal were added to the list of countries under increased monitoring;
• Phillipines has been removed from the list of countries under increased monitoring;
• Russia’s continued suspension remains in force.

There are more details on the FATF website.

Remember that the UK list of high risk countries (HRTC) now mirrors the FATF lists so CLC practices need to ensure that Enhanced Due Diligence (EDD) is applied when a client is “established” in a HRTC which means for an individual being resident in that country (not just having been born there) and for a company/legal person that means being incorporated in or having its principal place of business in that country. These lists also relate only to AML and not to sanctions (they are two separate and distinct regimes).

View the CLC’s AML Toolkit