Treasury has published an advisory on high risk third countries for money laundering and terrorist financing purposes following FATF’s latest meeting. The list of jurisdictions, which mirrors the FATF list, will soon be included in Schedule 3ZA of the MLRs. Altogether, Cameroon, Croatia and Vietnam will be added to the list with South Africa and Nigeria, and Cambodia and Morocco removed. The forthcoming legislative changes will take this into account as well as the additions FATF made in February, which have not yet been transferred into UK law. Confusingly, one piece of legislation published alongside the update removes Cambodia and Morocco from the list, but a further piece of legislation adding the new jurisdictions cannot be published until all full impact assessments have been completed. Alongside the legislation, Treasury has published its impact assessment on the enhanced due diligence on high risk third countries which will be affected by designations. The impact assessment says Treasury estimates that around 101,000 entities are within scope of the MLRs and, interestingly, makes a calculation on costs and benefits including working on the assumption that an average employee will read at 238 words per minute.
