ECSH31555 | FATF call for action countries and previous high-risk third countries schedules

From 30 June 2026, regulation 33(3) of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) - covering situations where enhanced due diligence is required - was amended to remove references to ‘high-risk third countries’ and replace them with ‘FATF call for action country’.

From 23 January 2024 until 29 June 2026, regulation 33(3) MLR 2017 referred to high-risk third countries as a country which is named on either of the High Risk Jurisdictions subject to a ‘Call for Action’ list or jurisdiction under ‘Increased Monitoring’ list, published by the Financial Action Task Force (FATF). These are often referred to as the ‘black and grey lists’.

The FATF reviews jurisdictions based on threats, vulnerabilities, or particular risks arising from the jurisdiction. You can read more about this here.

Before 30 June 2026, MLR 2017 referred to a list of high risk third countries. From 26 June 2017 until 25 March 2021 this list was maintained by the European Union. From 26 March 2021 to 22 January 2024 the list was published in Schedule 3ZA MLR 2017. The table below indicates the list of countries, dates they were added or removed and ‘Not applicable’ where they did not already exist on a list or did not carry forward.

This list is correct as of 30 June 2026.

For operational guidance on this subject, see ECSH33336.