Anti-money laundering

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Anti-money laundering

Updated list of high-risk and other monitored jurisdictions as of October 2025

20 Nov 2025
aat comment

FATF has announced the latest changes to high-risk third countries.

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) (Regulation 33(1)(b), MLR 2017). 

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 24 October 2025, with the following outcomes:

‘Black list’

Jurisdictions subject to a FATF call on its members and other jurisdictions to apply countermeasures (‘black list’).

No changes were made to black list countries.

The list of high-risk jurisdictions still includes the Democratic People’s Republic of Korea (DPRK), Iran, and Myanmar.

‘Grey list’

Jurisdictions under Increased Monitoring (‘grey list’).

Countries removed from the grey list

  • Burkina Faso
  • Mozambique
  • Nigeria
  • South Africa

No new jurisdictions were added to the grey list. The full list of grey list countries is available here.

What does this mean for your firm, including sole practitioners?

Consider whether the changes to the grey list mean your clients are no longer connected to a HRTC and review the level of customer due diligence required using a risk-based approach. Any changes made to the risk associated with a client, must be recorded in writing.

Ensure your clients’ onboarding procedures, Policies, Controls and Procedures (PCPs) and your firm-wide risk assessment 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 recourses.

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

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