Her Majesty’s Treasury (HMT) have published their advisory notice concerning risks posed by insufficient financial crime controls over particular jurisdictions.
In their note, HMT provides that:
• the Democratic People’s Republic of Korea should be considered as high risk and firms should apply counter measures and enhanced due diligence measures in accordance with the risks
• Iran should be considered as high risk and firms should apply enhanced due diligence measures in accordance with the risks and any other measures as specified by the Financial Action Task Force that have a similar effect in mitigating risks
• firms should take appropriate action to minimise the associated risks, which may include enhanced due diligence measures in high risk situations in relation to: the Bahamas, Botswana, Cambodia, Ghana, Iceland, Mongolia, Pakistan, Panama, Syria, Trinidad and Tobago, Yemen and Zimbabwe
Firms are advised to communicate internally, ensuring that Compliance, Risk Team and the Money Laundering Reporting and Nominated Officers are aware, together with an update for Board and Executive Teams, to ensure that their financial crime Policies and Procedures are updated, as necessary, in elation to existing, or potential exposures to the countries mentioned in the advisory notice.
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Please Note: This publication is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to. Readers should take legal advice before applying the information contained in this publication to specific issues or transactions.
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