The Financial Action Task Force (FATF) updated the list of high-risk countries (i.e., high-risk third countries, known as HRTCs) in October 2025. In response, both HM Treasury in the UK and the European Commission for the EU updated their lists. The U.S. utilises the FATF list for high-risk third countries.

What’s changed?

There were no new additions to the FATF grey list (jurisdictions under increased monitoring), and Burkina Faso, Mozambique, Nigeria, and South Africa have all been removed from the list. However, these jurisdictions remain on the European Commission’s list of high-risk third countries and continue to be subject to increased monitoring in the UK and EU.

Why is knowing what locations are flagged as high-risk important?

Read more about these latest updates:

FATF (global, U.S.): 

• Call to Action (“black list“): https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/Call-for-action-october-2025.html
• Increased Monitoring (“grey list“): https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2025.html

UK:

• In addition to FATF’s lists, the UK maintains its own list under MLRs Regulation 33(1)(b). This national list is published as Schedule 3ZA of the MLRs and is updated periodically via Statutory Instruments.
• If you are a UK-based AMP, you must use this list when applying Enhanced Due Diligence (EDD) – even if it slightly differs from the FATF lists.
• 27th October 2025 update: https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries–2

EU:

• The EU maintains its own high-risk country list, available on the European Commission website.
• 16th July 2025 announcement by European Commission: https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en
• EUR LEX listing of high-risk third countries: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02016R1675-20250805

U.S.:

• The US does not issue a standalone AML HRJ list but US authorities (FinCEN) recommend using FATF lists and impose financial sanctions on the most concerning jurisdictions.
  
• FinCEN guidance on FATF alignment: https://www.fincen.gov/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-3
• FATF public statements: https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions.html

What does this mean for your art business?

Your customer due diligence needs to reflect changes in high-risk third countries as the list/s evolve over time. The FATF updates three times per annum, which is often followed by both the UK and EU making changes. The good news is that the ArtAML™ platform automatically checks for high-risk jurisdictions (under standard due diligence) in association with your customer’s:

• Residential address (for private individuals and the UBOs of companies)
• Registered address (for companies)
• Source of funds (for all types of customer)
• Reliance partner (the Art Market Participant or regulated business upon whose AML checks you’re relying)
• If a high-risk (or bordering) jurisdiction is identified in our platform, a red flag is raised, which triggers conducting Enhanced Due Diligence. You will need to take a risk-based approach based on information related to the transaction, in context of the risks your own business faces of being a target of ML/TF activities.

Further reading

• Knowledge Base article on High-Risk Jurisdictions: https://knowledgebase.artaml.com/high-risk-jurisdictions-for-art-market-participants-why-does-this-matter-and-how-do-you-get-answers