The UK government’s publishing of the Money Laundering and Terrorist Financing (Amendment) (High-Risk Countries) Regulations 2021, along with an explanatory memorandum, is of significance due to the changes in relation to such nations.
The Regulations amend regulation 33(3)(a) of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs).
Inserted into the MLRs is Schedule 3ZA, which contains a list of high-risk third countries. The definition of a high-risk third country is no longer one that is designated so by a European Commission delegated act. It is now one that is included in the Schedule 3ZA list, as reflected by the amendment to regulation 39(4) of the MLRs.
The Regulations also repeal the retained EU law list of high-risk third countries recognised by the European Commission; which is superseded by the new list in Schedule 3ZA.
The countries on the Schedule 3ZA list are Albania, Barbados, Botswana, Burkina Faso, Cambodia, Cayman Islands, Democratic People’s Republic of Korea, Ghana, Iran, Jamaica, Mauritius, Morocco, Myanmar, Nicaragua, Pakistan, Panama, Senegal, Syria, Uganda, Yemen and Zimbabwe.