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pc nid 93421 Jun 23, 2026 csoo@vixio.com United Kingdom Competition and Markets Authority horizon scanning
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United Kingdom HM Treasury Issues Money Laundering Advisory Notice on High-Risk Third Countries

On June 19, 2026, HM Treasury published an advisory notice updating the list of high-risk third countries (HRTCs) under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs). The notice advises UK regulated businesses on enhanced customer due diligence (CDD) obligations in relation to jurisdictions identified by the Financial Action Task Force (FATF) as having strategic deficiencies in their anti-money laundering and counter-terrorism financing (AML/CTF) regimes. Under Regulation 33 of the MLRs, relevant persons must apply enhanced CDD and enhanced ongoing monitoring to business relationships with persons established in HRTCs, and to relevant transactions where either party is established in an HRTC. HRTCs are defined as countries appearing on the FATF's "High-Risk Jurisdictions subject to a Call for Action" or "Jurisdictions Under Increased Monitoring" lists. The FATF updates these lists three times annually following Plenary meetings in February, June, and October. The advisory notice identifies 28 jurisdictions under increased monitoring and three jurisdictions subject to a call for action: the Democratic People's Republic of Korea, Iran, and Myanmar. Of these, ten jurisdictions are also subject to UK financial sanctions measures, requiring firms to implement additional compliance measures. HM Treasury emphasises that relevant persons should apply a risk-based approach to enhanced due diligence, proportionate to identified risks, and should refer to sector-specific guidance for further compliance advice. The Money Laundering and Terrorist Financing (Amendment) Regulations 2026, laid before Parliament on March 25, 2026, narrows the scope of mandatory enhanced due diligence to only the "High-Risk Jurisdictions subject to a Call for Action" list, effective June 30, 2026. Relevant persons will continue considering FATF mutual evaluations as a geographical risk factor under Regulation 33(6)(c). This notice supersedes all previous HM Treasury advisory notices on this subject.

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United Kingdom HM Treasury Issues Money Laundering Advisory Notice on High-Risk Third Countries

On June 19, 2026, HM Treasury published an advisory notice updating the list of high-risk third countries (HRTCs) under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs). The notice advises UK regulated businesses on enhanced customer due diligence (CDD) obligations in relation to jurisdictions identified by the Financial Action Task Force (FATF) as having strategic deficiencies in their anti-money laundering and counter-terrorism financing (AML/CTF) regimes. Under Regulation 33 of the MLRs, relevant persons must apply enhanced CDD and enhanced ongoing monitoring to business relationships with persons established in HRTCs, and to relevant transactions where either party is established in an HRTC. HRTCs are defined as countries appearing on the FATF's "High-Risk Jurisdictions subject to a Call for Action" or "Jurisdictions Under Increased Monitoring" lists. The FATF updates these lists three times annually following Plenary meetings in February, June, and October. The advisory notice identifies 28 jurisdictions under increased monitoring and three jurisdictions subject to a call for action: the Democratic People's Republic of Korea, Iran, and Myanmar. Of these, ten jurisdictions are also subject to UK financial sanctions measures, requiring firms to implement additional compliance measures. HM Treasury emphasises that relevant persons should apply a risk-based approach to enhanced due diligence, proportionate to identified risks, and should refer to sector-specific guidance for further compliance advice. The Money Laundering and Terrorist Financing (Amendment) Regulations 2026, laid before Parliament on March 25, 2026, narrows the scope of mandatory enhanced due diligence to only the "High-Risk Jurisdictions subject to a Call for Action" list, effective June 30, 2026. Relevant persons will continue considering FATF mutual evaluations as a geographical risk factor under Regulation 33(6)(c). This notice supersedes all previous HM Treasury advisory notices on this subject.