EU High Risk Third Countries: Updated AML Policy

Explore the revised AMLD tackling high-risk third countries in the EU. Uncover the list of obliged entities and strategies to stay compliant.

Table of contents

Navigating the intricate landscape of Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) policies demands constant vigilance for businesses and financial institutions. In its tireless efforts to combat financial crimes and counter-terrorist financing, the European Union recently rolled out substantial updates to the Anti-Money Laundering Directive (AMLD).

This comprehensive guide examines the crucial facets of the revised countermeasures against money laundering and terrorist funding, focusing on high-risk third countries, dissecting their ramifications, and providing actionable insights to ensure compliance with the EU’s financial system.

Updated AMLD: Major Highlights

Here are the major highlights for the updated AMLD:

Expanded list of Obliged Entities

  • Diving into the complex landscape of money laundering regulations regarding the updated AMLD reveals an augmented list of entities in the high-risk third-world countries required to adhere to the AML/CFT regulations. A deliberate move to fortify the regulatory fabric includes crypto sector entities, luxury goods traders, professional football clubs, and their agents. This strategic broadening echoes a nuanced comprehension of the morphing landscape of financial fraud that needs to be assessed successively.
  • In the domain of Crypto-asset service providers (CASPs), a unique directive has surfaced, prompting a thorough examination of transactions surpassing the €1000 threshold. This nuanced approach acknowledges the peculiar risks interwoven in the crypto sector, shedding light on the EU’s commitment to nuanced regulations adaptable to the complex financial ecosystem.

High-Risk Third Countries

  • A pivot in the narrative unfolds with a heightened emphasis on EU high risk third countries. Entities under obligation must now employ additional measures and heightened due diligence for transactions and associations involving countries flagged as a significant risk by the Financial Action Task Force (FATF). A tacit acknowledgment of the evolving panorama echoes across high-risk third countries through this addition, displaying a readiness to confront significant threats.

Cash Payment Limits

  • To curtail illicit financial activities, an overarching EU-wide maximum limit of €10,000 for cash payments emerges. This substantial reduction in the maximum cash transaction limit isn’t just a figure; it’s a resounding declaration of the EU’s pledge to craft a transparent financial landscape.
  • Offering member states flexibility, the directive allows imposing lower maximum limits as deemed necessary. Additionally, for transactions between €3,000 and €10,000, obliged entities must identify and verify the individuals involved, further contributing to a more transparent financial landscape.

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Supervision and Risk Assessment

  • A significant stride in regulatory oversight involves member states ensuring effective supervision of obliged entities through a risk-based approach. This mandates reporting suspicions to Financial Intelligence Units (FIUs), fostering a more proactive stance in AML/CFT efforts.
  • The increased focus on risk assessment, as the Financial Action Task Force encourages, is a crucial element in the fight against financial crimes, providing insights into the EU’s dedication to creating a robust regulatory framework.

Enhanced Due Diligence Measures

  • Amidst the ever-shifting landscape of financial crimes, the introduction of Enhanced Due Diligence (EDD) measures for cross-border correspondent relationships within the crypto-asset sector marks a significant advancement.
  • Financial institutions are now required to implement enhanced due diligence for business dealings with high-net-worth individuals overseeing substantial assets. This strategic move underscores the importance of customized due diligence, seamlessly aligning with the EU’s dedication to precise and impactful regulatory measures to combat money laundering and terrorist financing.
Key updates to the 7th AML directive

About High-Risk Third Countries

The high-risk third countries list, established by the European Commission based on the 4th Anti-Money Laundering Directive, identifies jurisdictions with weak anti-money laundering and counter-terrorist financing controls, posing threats to the EU’s financial system. To address these risks, banks and other financial institutions must apply stricter due diligence measures on transactions involving these countries, which are determined by the Commission’s evaluation of national efforts and collaboration with international partners like the FATF.

Updated List of High-Risk Third Countries in the EU

On December 12, 2023, the European Commission embraced a fresh Delegated Regulation concerning third countries with strategic shortcomings in their AML/CFT frameworks. This Delegated Regulation serves as an amendment to Delegated Regulation (EU) 2016/1675.

The jurisdictions listed below are recognized for possessing strategic deficiencies in their AML/CFT frameworks:

High-Risk Third CountryDate of Entry
Afghanistan23 September 2016
Barbados1 October 2020
Burkina Faso13 March 2022
Cameroon18 October 2023
Democratic Republic of the Congo16 March 2023
Gibraltar16 March 2023
Haiti13 March 2022
Iran23 September 2016
Jamaica1 October 2020
Mali13 March 2022
Mozambique16 March 2023
Myanmar1 October 2020
Nigeria16 July 2023
North Korea23 September 2016
Panama1 October 2020
Philippines13 March 2022
Senegal13 March 2022
South Africa16 July 2023
South Sudan13 March 2022
Syria23 September 2016
Tanzania16 March 2023
Trinidad and Tobago6 March 2018
Uganda23 September 2016
United Arab Emirates16 March 2023
Vanuatu23 September 2016
Vietnam18 October 2023
Yemen23 September 2016

What Should Companies Do?

With the updated AMLD, companies are urged to embrace a multi-faceted strategy when conducting business in high-risk third countries:

  1. Engage in Enhanced Due Diligence: Dive deep into client understanding, as detailed in our comprehensive guide on KYC and customer due diligence. In a regulatory landscape of high-risk countries, the EU’s stress on enhanced due diligence echoes the necessity for thorough customer scrutiny.
  2. Immerse in Thorough Risk Assessment: Explore the insights in our AML risk assessment guide, peeling back the layers of comprehensive risk evaluation. The emphasis on risk assessment within the updated AMLD signals a shift toward a proactive, risk-centric approach.
  3. Maintain Meticulous Recordkeeping and Reporting:Navigate the terrain of robust recordkeeping and real-time reporting, as dissected in our foray into AML transaction monitoring. The spotlight on reporting and recordkeeping within the updated AMLD resonates with worldwide trends in the relentless fight against financial crimes.
  4. Implement Ongoing Transaction Monitoring: In the fluidity of financial transactions, increased monitoring is essential for internal security. Our guide on AML transaction monitoring delves into effective strategies for ongoing vigilance. The EU’s emphasis on increased monitoring signals a move towards a dynamic and adaptive regulatory environment.
How to stay compliant

Stay Compliant with EU AMLDs

Ensuring compliance with the evolving AML landscape is a nuanced task. Here, HyperVerge stands as a valuable ally, furnishing comprehensive solutions to navigate the intricacies of the proposed 7th EU AMLD. To uncover how HyperVerge can bolster your company in maintaining compliance, delve into our expansive AML compliance guide.

AML compliance with HyperVerge

In summary, the updated AMLD reaffirms the EU’s unwavering commitment to bolstering its financial defenses. As businesses navigate these fresh requirements, adopting a proactive stance toward compliance becomes imperative. Whether it is a high-risk third country or any other nation, a solution like HyperVerge furnishes essential tools to guarantee adherence to the dynamic regulatory landscape, nurturing a safer and more secure financial ecosystem. Stay well-informed, stay compliant, and contribute to the sustainable development of a resilient financial infrastructure by taking your next step today!

Nupura Ughade

Nupura Ughade

Content Marketing Lead

With a strong background B2B tech marketing, Nupura brings a dynamic blend of creativity and expertise. She enjoys crafting engaging narratives for HyperVerge's global customer onboarding platform.

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