Kayleigh Smale

AML, Compliance & Anti-Fraud Specialist

Updates to The Financial Action Task force (FATF)’s lists: What does this mean for law firms?

The Financial Action Task force (FATF) had its last plenary of the year last week where it decided which countries should should be added, removed or remain on its lists of Jurisdictions under Increased Monitoring (the grey list) and The High Risk Jurisdictions subject to a call for action (the black list)

This update directly impacts law firms and their compliance obligations because the UK’s High Risk Third Country list mirrors FATF’s lists.


Why is this important?

Law firms need to keep a close eye on clients—new and existing—who live, work, or do business in a High Risk Third Country (HRTC). When a country makes the HRTC list, enhanced due diligence and ongoing monitoring become essential.

This is why staying updated on the HRTC list is a must! Firms should have a solid process for quickly checking client statuses whenever there’s a list change.

And remember, even if a client wasn’t initially flagged as high risk, that can change overnight if they’re in a country newly added to the HRTC list.


Updated UK list of High Risk Third Countries - October 2024

Algeria Monaco
Angola Mozambique
Bulgaria Myanmar
Burkina Faso Namibia
Cameroon Nigeria
Côte d’Ivoire Philippines
Croatia South Africa
DPRK South Sudan
DR Congo Syria
Haiti Tanzania
Iran Venezuela
Kenya Vietnam
Lebanon Yemen
Mali



How does Legl help?

We track updates to the HRTC list, so you don’t have to!

Legl’s MLRO Oversight dashboard enables firms to quickly verify if any client’s address is located within a HRTC.

With the MLRO Oversight dashboard, you can also conduct audits at any time to identify clients with addresses in these jurisdictions.

This functionality empowers your firm to meet regulatory obligations with confidence and efficiency.