High Risk Third Countries

The image above and quote below is from Ray Blake, co-host of the excellent podcast “The Dark Money Files”.

“Following the FATF Plenary, we have a slightly different spread of High Risk Third Countries. This version, like the last - itself only two weeks old - feels transitional given the imminently-promised UK move to disregard the grey list and define HR3Cs as simply the three black list countries. Still, as of now, this Venn diagram describes the legal obligation to apply EDD when your customer is based in one of the listed countries, based on whether you are operating in the UK or the EU/EEA.”

Right now - UK-based Firms must apply Enhanced Due Diligence (EDD) to customers based in the green or yellow sections. As Ray’s quote says, the UK has signalled its intent to abandon the obligation to apply EDD on grey list countries, but that is not the case right now.

For full context, we recommend that you listen to the podcast.

High Risk Third Countries can be a confusing area, and exists alongside, not instead of Firm’s own risk assessments.

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