On, 22 January 2024 the HM Treasury (HMT) issued Guidance on the changes to The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the MLRs), amending the definition of High Risk Third Countries (HRTC).
The changes are as follows:
- Schedule 3ZA is repealed.
- High risk third countries (HRTCs) will now be defined as those who are subject to increased monitoring or to a call for action by FATF – the list can be found here.
- There is no immediate change to which countries are classified as HRTCs, but FATF reviews its monitoring and calls to action at the conclusion of each plenary – the dates of which can be found here.
The immediate effect for the regulated population is that the onus has shifted away from HMT to keep this list updated – notaries will now need to keep a closer eye on FATF’s proceedings to stay up to date. The next update to the FATF lists is expected on the final day of the FATF Plenary, on 23 February 2024.