Under the 4AMLD and 5AMLD, Firms are required to apply enhanced due diligence on customers and transactions involving countries identified by the Commission as “high-risk third countries”. Announcing their new methodology for listing countries together with the financial crime action plan, the EU Commission has released the 2020 list of “high-risk third countries”.

New to the list this year (although measures are not yet in force) are: Bahamas, Barbados, Botswana, Cambodia, Ghana, Jamaica, Mauritius, Mongolia, Myanmar, Nicaragua, Panama, and Zimbabwe.

Coming off the list from last year are: Bosnia-Herzegovina, Ethiopia, Guyana, Laos, Sri Lanka, and Tunisia.

UK regulated entities have a specific obligation under the Money Laundering Regulations 2017 (as amended 2019), to apply EDD where either of the parties to a transaction is established in a high-risk third country.