Updated list of high-risk and other monitored jurisdictions as of February 2026

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Find out the outcomes of the latest FATF plenary.

Under the UK’s legislation, any business relationship or transaction with a person established in a high-risk third country (HRTC) must be subject to enhanced due diligence (EDD). Under Regulation 33(3)(a) MLR 2017, a HRTC is defined as:

“a country named on either of the following lists published by the Financial Action Task Force as they have effect from time to time

  • high-risk jurisdictions subject to a call for action (i.e. ‘black list’)
  • jurisdictions under increased monitoring (i.e. ‘grey list’)”

The latest Financial Action Task Force (FATF) Plenary concluded on 13 February 2026, with the following outcomes:

‘Black list’

  • No changes were made to black list countries.

Jurisdictions subject to a FATF call on its members and other jurisdictions to apply countermeasures include:

  • Democratic People’s Republic of Korea (DPRK)
  • Iran

Jurisdiction subject to a FATF call on its members and other jurisdictions to apply enhanced due diligence measures proportionate to the risks arising from the jurisdiction. The FATF calls for the application of enhanced due diligence – and not countermeasures – on the below jurisdiction:

  • Myanmar

‘Grey list’

Countries added to the grey list

  • Kuwait
  • Papua New Guinea

No jurisdictions were removed from the grey list. Here is the full list of grey list countries.

What does this mean for you?

Review your existing client list to identify whether any of your clients are now considered to be established in a HRTC and undertake and record appropriate enhanced customer due diligence (EDD) measures. It also includes funds coming from HRTC, beneficial owners or transactions connected to HRTC.

Guidance around EDD measures can be found in Section 5 of AML Guidance for the Accountancy Sector (PDF).

Ensure your clients’ onboarding procedures, ongoing monitoring, Policies, Controls and Procedures (PCPs) and your firm-wide risk assessment (FWRA) refer to the FATF’s lists. These lists are updated three times a year, on the final day of each FATF plenary meeting, held every February, June and October.

AAT’s AML helpline

AAT’s AML helpline offers advice for AAT-supervised firms on all aspects of complying with the Money Laundering Regulations, such as advice on how to report suspected illegal activity. To discuss any questions you might have, call us on +44 (0)20 7367 1347 or email [email protected]. We also have a dedicated page with the AML resources.

Future of supervision

On 21 October 2025, the Government confirmed that the AML supervision for accountancy, legal and Trust and Company Service Provider sectors will move to a single professional services supervisor (SPSS), specifically the Financial Conduct Authority.

While this is a big shift, implementation is likely to take years. In the meantime, AAT will continue as the AML supervisor for our licensed members and carry out our normal responsibilities, including Practice Assurance Reviews and risk assessment activities. Therefore, our members must ensure full compliance with the MLR 2017. Read more on the consultation response here.

Further guidance and support on risk management and other components of Money Laundering Regulations compliance is available on our AML webpage. You can also contact us on +44 (0)20 7367 1347 or via email at [email protected].

AAT Comment offers news and opinion on the world of business and finance from the Association of Accounting Technicians.

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