Europe  

October 

American Samoa  Anguilla 
The Bahamas  Fiji 
Guam  Palau 
Panama  Samoa 
Trinidad and Tobago  Turks and Caicos Islands 
US Virgin Islands  Vanuatu 


June

United Kingdom 

September 

  1. Paragraph 5.5.11 and Annex 5-IV – as relating to high-risk third countries (HRTC) EDD
    Firms must undertake enhanced due diligence on business relationships connected to the UK high risk third country list.  The consultation further provides: “All of these additional EDD measures must be applied to new and  existing customers
  2. Paragraph 5.3.129A and paragraphs 5.3.258-5.3.282 – as relating to trusts
    Firms must obtain proof of registration… in the case of in-scope trusts proof of registration with the Trust Registration Service may be obtained from the  agent or trustee of the trust
    The consultation includes the positive duty on UK firms to report discrepancies: “For further information on discrepancy reporting for in-scope trusts (including what HMRC considers a material discrepancy) see: https://www.gov.uk/hmrc-internal-manuals/trust-registration-service-manual 
  3. Chapters 4 and 7 – as relating to proliferation financing
    This adds proliferation financing as a distinct area of risk that sits alongside AML/CFT 

August 

July

  • HM Treasury Advisory Notice: High Risk Third Countries
    HM Treasury updated the list of high risk third countries which requires regulated businesses to apply enhanced customer due diligence measures and enhanced ongoing monitoring in any business relationships.
    The countries listed are as follows: Albania, Barbados, Burkina Faso, Cambodia, Cayman Islands, DPRK*, Gibraltar, Haiti, Iran*, Jamaica,  Jordan, Mali*, Morocco, Myanmar*, Nicaragua*, Pakistan, Panama, Philippines, Senegal, South Sudan*, Syria*, Türkiye, Uganda, United Arab Emirates, Yemen*
    *These jurisdictions are subject to financial sanctions measures

Guernsey 

July

Jersey 

October

  • The AML/CFT assessment body of the Council of Europe (MONEYVAL) is due to evaluate the Island in 2023. 

United States of America 

September 

Cayman Islands 

October

  • General Licence Under Russian Sanctions Issued
    Russia sanctions update: General Licence GL/2022/0001 allows a Relevant Investment Fund or Fund Manager to redeem, withdraw or otherwise deal with an investment interest and make payments for basic needs, routine holding and maintenance and legal fees from frozen accounts.

    Persons intending to use General Licence GL/2022/0001 must consult a copy of the licence for full details of the relevant permissions and usage requirements.
    As outlined in General Licence GL/2022/0001, a Relevant Investment Fund or Fund Manager that is regulated by the Cayman Islands Monetary Authority (the “Authority”) must notify the Authority of its use of this licence within three (3) business days. Such notifications should be sent to [email protected]  

Singapore 

August

  • MAS Information Paper for Asset Managers
    The information paper issued by the Monetary Authority of Singapore (MAS) provides asset managers the supervisor’s expectations for meeting AML/CFT obligations.  Any gaps in the asset manager’s process and controls should be remedied in a timely manner.