ECSH31555 - Schedule 3ZA - High-Risk Third Countries
From 23 January 2024, Regulation 33(3) of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) defined a high-risk third country 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.
Prior to 23 January 2024, a list of high-risk third countries:
- Up to 25 March 2021 was maintained on the EU List.
- From 26 March 2021 to 22 January 2024 was maintained on 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 24 February 2026.
For operational guidance on high-risk third countries, see ECSH33336.
|
Country |
Date added to EU list |
Date removed from EU list |
Date added to Schedule 3ZA |
Date removed from Schedule 3ZA |
Date of effect under FATF |
Date removed from FATF |
|
Afghanistan |
23 Sept 2016 |
Not applicable |
Not applicable |
Not applicable |
Not applicable |
Not applicable |
|
Albania |
Not applicable |
Not applicable |
26 Mar 2021 |
5 Dec 2023 |
Not applicable |
Not applicable |
|
Algeria |
25 October 2024 |
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|
Angola |
25 October 2024 |
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|
Bahamas |
1 Oct 2020 |
13 Mar 2022 |
Not applicable |
Not applicable |
Not applicable |
Not applicable |
|
Barbados |
1 Oct 2020 |
Not applicable |
26 Mar 2021 |
Not applicable |
23 January 2024 |
23 February 2024 |
|
Bolivia |
13 June 2025 |
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|
Bosnia and Herzegovina |
13 Feb 2018 |
9 Jul 2020 |
Not applicable |
Not applicable |
Not applicable |
Not applicable |
|
Botswana |
1 Oct 2020 |
13 Mar 2022 |
26 Mar 2021 |
2 Nov 2021 |
Not applicable |
Not applicable |
|
Bulgaria |
Not applicable |
Not applicable |
5 Dec 2023 |
Not applicable |
23 January 2024 |
|
|
Burkina Faso |
13 Mar 2022 |
Not applicable |
26 Mar 2021 |
Not applicable |
23 January 2024 |
24 October 2025 |
|
Burma -see Myanmar |
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|
Cambodia |
1 Oct 2020 |
17 May 2023 |
26 Mar 2021 |
27 Jun 2023 |
Not applicable |
Not applicable |
|
Cameroon |
18 Oct 2023 |
Not applicable |
5 Dec 2023 |
Not applicable |
23 January 2024 |
|
|
Cayman Islands |
13 Mar 2022 |
12 Dec 2023 |
26 Mar 2021 |
5 Dec 2023 |
Not applicable |
Not applicable |
|
Côte d'Ivoire |
25 October 2024 |
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|
Croatia |
Not applicable |
Not applicable |
5 Dec 2023 |
Not applicable |
23 January 2024 |
13 June 2025 |
|
Democratic People’s Republic of Korea (DPRK) |
23 Sept 2016 |
Not applicable |
26 Mar 2021 |
Not applicable |
23 January 2024 |
|
|
Democratic Republic of the Congo |
16 Mar 2023 |
Not applicable |
15 Nov 2022 |
Not applicable |
23 January 2024 |
|
|
Ethiopia |
13 Feb 2018 |
9 Jul 2020 |
Not applicable |
Not applicable |
Not applicable |
Not applicable |
|
Ghana |
1 Oct 2020 |
13 Mar 2022 |
26 Mar 2021 |
13 Jul 2021 |
Not applicable |
Not applicable |
|
Gibraltar |
16 Mar 2023 |
Not applicable |
12 Jul 2022 |
Not applicable |
23 January 2024 |
23 February 2024 |
|
Guyana |
13 Feb 2018 |
9 Jul 2020 |
Not applicable |
Not applicable |
Not applicable |
Not applicable |
|
Haiti |
13 Mar 2022 |
Not applicable |
13 Jul 2021 |
Not applicable |
23 January 2024 |
|
|
Iran |
23 Sept 2016 |
Not applicable |
26 Mar 2021 |
Not applicable |
23 January 2024 |
|
|
Iraq |
13 Feb 2018 |
13 Mar 2022 |
Not applicable |
Not applicable |
Not applicable |
Not applicable |
|
Jamaica |
1 Oct 2020 |
Not applicable |
26 Mar 2021 |
Not applicable |
23 January 2024 |
28 June 2024 |
|
Jordan |
13 Mar 2022 |
12 Dec 2023 |
2 Nov 2021 |
5 Dec 2023 |
Not applicable |
Not applicable |
|
Kenya |
23 February 2024 |
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|
Kuwait |
13 February 2026 |
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|
Lao PDR (Laos) |
13 Feb 2018 |
9 Jul 2020 |
Not applicable |
Not applicable |
21 February 2025 |
|
|
Lebanon |
25 October 2024 |
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|
Mali |
13 Mar 2022 |
Not applicable |
2 Nov 2021 |
Not applicable |
23 January 2024 |
13 June 2025 |
|
Malta |
Not applicable |
Not applicable |
13 Jul 2021 |
12 Jul 2022 |
Not applicable |
Not applicable |
|
Mauritius |
1 Oct 2020 |
13 Mar 2022 |
26 Mar 2021 |
2 Nov 2021 |
Not applicable |
Not applicable |
|
Monaco |
28 June 2024 |
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|
Mongolia |
1 Oct 2020 |
7 Feb 2021 |
Not applicable |
Not applicable |
Not applicable |
Not applicable |
|
Morocco |
13 Mar 2022 |
17 May 2023 |
26 Mar 2021 |
27 Jun 2023 |
Not applicable |
Not applicable |
|
Mozambique |
16 Mar 2023 |
Not applicable |
15 Nov 2022 |
Not applicable |
23 January 2024 |
24 October 2025 |
|
Myanmar/Burma |
1 Oct 2020 |
Not applicable |
26 Mar 2021 |
Not applicable |
23 January 2024 |
|
|
Namibia |
23 February 2024 |
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|
Nepal |
21 February 2025 |
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|
Nicaragua |
1 Oct 2020 |
19 Dec 2022 |
26 Mar 2021 |
15 Nov 2022 |
Not applicable |
Not applicable |
|
Nigeria |
16 Jul 2023 |
Not applicable |
5 Dec 2023 |
Not applicable |
23 January 2024 |
24 October 2025 |
|
North Korea – see Democratic People’s Republic of Korea |
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|
Pakistan |
22 Oct 2018 |
19 Dec 2022 |
26 Mar 2021 |
15 Nov 2022 |
Not applicable |
Not applicable |
|
Panama |
1 Oct 2020 |
Not applicable |
26 Mar 2021 |
5 Dec 2023 |
Not applicable |
Not applicable |
|
Papua New Guinea |
13 February 2026 |
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|
Philippines |
13 Mar 2022 |
Not applicable |
13 Jul 2021 |
Not applicable |
23 January 2024 |
21 February 2025 |
|
Senegal |
13 Mar 2022 |
Not applicable |
26 Mar 2021 |
Not applicable |
23 January 2024 |
25 October 2024 |
|
South Africa |
16 Jul 2023 |
Not applicable |
5 Dec 2023 |
Not applicable |
23 January 2024 |
24 October 2025 |
|
South Sudan |
13 Mar 2022 |
Not applicable |
13 Jul 2021 |
Not applicable |
23 January 2024 |
|
|
Sri Lanka |
6 Mar 2018 |
9 July 2020 |
Not applicable |
Not applicable |
Not applicable |
Not applicable |
|
Syria |
23 Sep 2016 |
Not applicable |
26 Mar 2021 |
Not applicable |
23 January 2024 |
|
|
Tanzania |
16 Mar 2023 |
Not applicable |
15 Nov 2022 |
Not applicable |
23 January 2024 |
13 June 2025 |
|
Trinidad and Tobago |
6 Mar 2018 |
Not applicable |
Not applicable |
Not applicable |
Not applicable |
Not applicable |
|
Tunisia |
6 Mar 2018 |
9 Jul 2020 |
Not applicable |
Not applicable |
Not applicable |
Not applicable |
|
Turkey/Türkiye |
Not applicable |
Not applicable |
2 Nov 2021 |
Not applicable |
23 January 2024 |
28 June 2024 |
|
Uganda |
23 Sept 2016 |
Not applicable |
26 Mar 2021 |
Not applicable |
23 January 2024 |
23 February 2024 |
|
United Arab Emirates |
16 Mar 2023 |
Not applicable |
29 Mar 2022 |
Not applicable |
23 January 2024 |
23 February 2024 |
|
Vanuatu |
23 Sept 2016 |
Not applicable |
Not applicable |
Not applicable |
Not applicable |
Not applicable |
|
Venezuela |
28 June 2024 |
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|
Vietnam |
18 Oct 2023 |
Not applicable |
5 Dec 2023 |
Not applicable |
23 January 2024 |
|
|
Virgin Islands (UK) |
13 June 2025 |
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|
Yemen |
23 Sept 2016 |
Not applicable |
26 Mar 2021 |
Not applicable |
23 January 2024 |
|
|
Zimbabwe |
1 Oct 2020 |
19 Dec 2022 |
26 Mar 2021 |
29 Mar 2022 |
Not applicable |
Not applicable |