Anti Money Laundering Update – July 2022

This month sees some more compliance changes for firms to deal with in the form of changes to the Anti Money Laundering regime. The list of high-risk countries is being updated again on 11 July, and the LSAG guidance has now been approved by the Treasury.

The situation in relation to AML and sanctions is very fast moving at the moment, at least in part due to the ongoing issues with Russia. It is therefore interesting to note that Russia is still not appearing in the list of high-risk countries despite the sanctions that are being imposed.

On 17 June 2022 the Financial Action Task Force (FATF) updated its list identifying jurisdictions with strategic deficiencies in their AML/CTF regimes. Gibraltar has been added to the list and Malta removed.

High Risk Third Country

The UK’s High Risk Third Country list will be updated on 11 July 2022 to reflect these changes and sees Malta being removed and Gibraltar added in line with the FATF changes. These changes that will come into force under the Money Laundering and Terrorist Financing (High-Risk Countries) (Amendment) (No. 2) Regulations 2022.

Due to the frequency of the changes, it is always worth checking the list when dealing with clients that have connections outside the UK, or where money will be coming into the firm’s client account from foreign countries. Further information on the changes, and the full list of high-risk countries, can be found at:

Full list of high-risk countries

Additionally, the Legal Sector Affinity Group (LSAG) guidance has finally been approved by the Treasury. There are some minor changes to the draft guidance which can be found via the main link below and then by following the ”July 2022 changes” link.

The most significant changes are:

• The emphasis that beneficial owners’ identities must be verified to the same standard as would apply to a client that is a natural person,and
• Redirecting away from the old EU High Risk Third Country lists and towards the UK’s own list as referred to above.
  Full details can be found at:

Redirecting away from the old EU High Risk Third Country lists and towards the UK’s own list

For more information on how we can help your company deal with money laundering compliance, see our AML service section.