On 10 January 2022, the European Commission published an amendment to the delegated regulation of high-risk jurisdictions for anti-money laundering and counter terrorist financing.

The EU’s prescriptive list contains details of third-country jurisdictions which have strategic deficiencies in their Anti-Money Laundering / Counter Terrorist Financing (AML/CFT) regimes that pose significant threats to the financial system of the European Union must be identified in order to protect the proper functioning of the internal market.

The EU commission see the following countries as having strategic deficiencies in their AML/CFT regime: 

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For global companies, particularly in the financial services sector, sanctions compliance is becoming ever more fraught. Payments and money transfers are becoming ever more globalised, and new businesses are popping up to take advantage of a booming market. But when it comes to sanctions compliance, the costs of getting it wrong are rising.

Payoneer is a firm specialising in business-to-business cross-border payments. It is used by global leaders like Airbnb, Amazon, Google and Upwork to facilitate cross-border wire transfers, online payments, and debit card services. The company also offers facilities for small and medium-sized businesses to send payments anywhere in the world, quickly and cheaply.

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When the clock struck 11pm on 31 December 2020, the UK stopped applying EU sanctions and its own autonomous sanctions regime came into force. While the UK sanctions regime substantially does the same thing as the EU one, the lists of sanctioned entities may not be exactly identical. Importantly, UK sanctions may apply to non-UK sanctions and non-UK nationals, so it is important to stay up to date.

Brexit means that a company that operates in the UK and the EU is subject to at least two separate sanctions regimes. Therefore sanctions compliance has never been more important.

The UK has been preparing for this change for several years. This preparation includes the 2018 Sanctions and Anti-Money Laundering Act and the Global Human Rights Sanctions Regulations 2020. Additionally, over 30 statutory instruments have been laid to ensure a smooth transition to the new UK sanctions regime. 

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