AML Updates for High Risk Third Countries 

Cover Image for AML Updates for High Risk Third Countries 

| Sinead Gortland

Following recommendations from Financial Action Task Force (FATF) the EU Commission has confirmed the following updates to the High Risk Third countries list:

New Additions

  1. Algeria
  2. Angola
  3. Côte d’Ivoire
  4. Kenya
  5. Laos
  6. Lebanon
  7. Monaco
  8. Namibia
  9. Nepal, and
  10. Venezuela

Removed from the list;

  • Barbados
  • Gibraltar
  • Jamaica
  • Panama
  • the Philippines
  • Senegal
  • Uganda, and
  • the United Arab Emirates

Those added to the list of high-risk third countries which have provided a written high-level political commitment to address the identified deficiencies and have developed an action plan with the FATF.

What does this mean for you?

  1. As Ireland is covered by the AML framework, you will be required to apply Enhanced Due Diligence (EDD) in transactions involving these countries that have been added.
  2. You should also review your current client list and correct your processes for those removed (assuming there isn’t any other reason EDD shouldn’t be applied).

There is not an exact date for when the list is formally amended as the update of the list takes the legal form of a delegated regulation, which will enter into force after scrutiny and non-objection of the European Parliament and the Council within a period of one month (which can be prolonged for another month).

How can we help?

At CPDStore.ie we have a number of AML courses available.

We also have a list of resources and templates available Accountants Resource Centre including:

  1. AML Firm Action Plan
  2. Guidance Manual
  3. Procedures Manual
  4. Sample Detailed Client List Risk Assessment
  5. Sample Firm Business Risk Assessment
  6. OmniPro Sample CDD Builder

For those looking for more tailored training we also offer In House Training for AML to meet the needs of the individual practice.

The contents of this article are meant as a guide only and are not a substitute for professional advice. The authors accept no responsibility for any action taken, or refrained from, as a result of the material contained in this document. Specific advice should be obtained before acting or refraining from acting, in connection with the matters dealt with in this article.

Image of Sinead Gortland

About the Author

Sinead is a key member of the OmniPro Corporate Consultants Technical Support team providing advice and support in relation to Company Law and Company Secretarial procedures. In addition, Sinead is responsible for carrying out Section 343 applications to the District Court, Company Restorations, Annual Compliance, Company Conversions and Company Law Compliance. Sinead joined OmniPro in 2016 and quickly became an integral member of our Company Secretarial team. She started off her career in OmniPro as part of our Company Formations team building up her experience and knowledge before eventually moving into Company Secretarial. Sinead has a Masters Degree from Maynooth University.