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Sanctions List Updates 2024: Gibraltar Removed as High-Risk Jurisdiction

The Financial Action Task Force (FATF) has released its latest list of high-risk third countries, with several significant updates. Effective from February 23, 2024, the list has seen changes in the status of various jurisdictions.

New High-Risk Jurisdictions

The updated list now includes:

  • Kenya: Subject to additional financial sanctions measures, requiring firms to take enhanced due diligence (EDD) when dealing with individuals or entities from this jurisdiction.
  • Namibia: Subject to additional financial sanctions measures, requiring firms to take enhanced due diligence (EDD) when dealing with individuals or entities from this jurisdiction.

Removed from the List

The following countries have been removed from the list of high-risk third countries:

  • Barbados
  • Gibraltar: No longer required to implement EDD measures for businesses operating in this jurisdiction.
  • Uganda
  • United Arab Emirates: No longer required to implement EDD measures for businesses operating in this jurisdiction.

Updated Definition of High-Risk Third Countries

HM Treasury has amended the definition of high-risk third countries, removing Schedule 3ZA from the Money Laundering Regulations 2017. Instead, regulation 33(3)(a) now defines a high-risk third country as one that is listed on either the FATF’s high-risk jurisdictions subject to a call for action or jurisdictions under increased monitoring.

Upcoming Updates

The next update to the list is expected on June 28, 2024. The dates of these meetings are published several months in advance in the FATF event calendar.

Impact on UK Businesses

The updated list affects businesses operating in the UK, which must now apply EDD measures when dealing with individuals or entities from high-risk jurisdictions. The UK is entitled to amend its own list of high-risk countries under section 49 of the Sanctions and Anti Money Laundering Act 2018.

For more information on the updated list and guidance on appropriate EDD measures, businesses can consult the HM Treasury’s advisory notice on high-risk third countries.