Updated list of high-risk third countries as of June 2025

FATF has announced the latest changes to high-risk third countries. Check if you’re at risk.

Under the UK’s legislation, any business relationship 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 13 June 2025, with the following outcomes:

1.    The FATF suspension of the Russian Federation continues to stand.

2.    The following changes were made to the list of Jurisdictions under Increased Monitoring (‘grey list’).

Countries added to the grey list

• Bolivia
• British Virgin Islands

Countries removed from the grey list

• Croatia
• Mali
• United Republic of Tanzania  

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

Firms must:

Review their existing client list to identify whether any of their clients are now considered to be established in a HRTC and undertake and record appropriate enhanced customer due diligence (EDD) measures. Guidance around EDD measures can be found in Section 5 of AML Guidance for the Accountancy Sector (PDF).

Consider whether the changes mean their clients are no longer connected to a HRTC and consider the level of customer due diligence required using a risk-based approach.

Ensure their client onboarding procedures, Policies, Controls and Procedures (PCPs) and their 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.

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