The Financial Action Task Force (FATF) updated the list of high-risk countries (i.e., high-risk third countries, known as HRTCs) in October 2024. In response to that, HM Treasury in the UK published an update.The U.S. has continued to keep the sanctions program and country information updated, whereas the EU last updated HRTCs in 2023.

What’s changed?

Notably, Monaco has been added as a high-risk jurisdiction (grey list) on both the FATF and UK lists. Taking risk a step further than FATF’s updated list, the UK has added seven jurisdictions to the black list (in addition to Iran, Myanmar and North Korea): Congo, Haiti, Mali, South Sudan, Syria, Venezuela and Yemen.

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

Read more about these latest updates

• FATF – Call to Action (“black list”): https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/Call-for-action-october-2024.html
  
• FATF – Increased Monitoring (“grey list”): https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2024.html
• UK update: https://assets.publishing.service.gov.uk/media/673c504972f19089dfdadf58/Advisory_Notice_FATF_list_changes_Oct_2024.pdf
• EU: https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en
• U.S.: https://ofac.treasury.gov/sanctions-programs-and-country-information

What does this mean for your art business?

The ArtAML™ platform automatically checks for high risk jurisdictions, and countries that border high-risk jurisdictions, in association with:

• 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.

Not yet using ArtAML™ for compliance checks?

Or need to do a manual high-risk jurisdiction check? Review the current lists of high risk jurisdictions via the following links:

• UK list of high risk jurisdictions
• EU list of high risk jurisdictions
• USA list of high risk jurisdictions

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Blog post last updated 16th January 2025.