ML High Risk countries re-defined

From 22 January, a change to the MLRs means that Treasury will no longer periodically update Schedule 3ZA to the MLRs.  The definition of “High risk third country” is now a country named on the FATF lists of high-risk jurisdictions subject to a call for action or jurisdictions under increased monitoring. So the list at any given time will be the list then current on the FATF website (which, in turn updates three times a year, after the plenary meeting in February, June and October).

As at the date of the change, the MLR list and the FATF list were the same, so MLR firms will not need to carry out any gap analysis or new work in relation to existing customers provided they had applied appropriate EDD under the MLR list.