HM Treasury updates Money Laundering Advisory Notice following FATF June 2026 plenary changes to High Risk Third Countries list
HM Treasury updated its Money Laundering Advisory Notice in June 2026, following changes agreed at the Financial Action Task Force (FATF) plenary meeting that month. The notice, which sets out which countries qualify as High Risk Third Countries (HRTCs) as defined in the Money Laundering Regulations (MLR), was last substantively updated on 22 June 2026 to reflect both the June 2026 and February 2026 FATF plenary decisions on additions and removals from the HRTC list. The advisory notice is a live document that tracks FATF list changes in near real time, having been updated seven times since February 2024. Under the Money Laundering Regulations, UK regulated firms including banks, law firms, accountants and estate agents are required to apply enhanced due diligence (EDD) measures to business relationships or transactions involving parties from HRTCs. The notice was originally published in March 2021 and has been updated consistently to maintain alignment with FATF's rolling assessments of jurisdictions with unsatisfactory anti-money laundering and counter-terrorist financing controls. The page confirmed as the current state on 11 November 2026 reflects the June 2026 update as the operative version.
Why this matters
FATF plenary decisions directly translate into compliance obligations for every UK-regulated firm through the Money Laundering Regulations, making each update to the HM Treasury notice an operational compliance event rather than merely a policy signal. Firms that fail to apply enhanced due diligence to clients or transactions connected to newly listed jurisdictions face regulatory enforcement risk from the FCA, HMRC, or sector supervisors. The frequency of updates in 2026 (February and June plenaries both triggering changes) reflects the continuing pace of FATF mutual evaluation cycles and the growing number of jurisdictions under active review.
On the Ground
This update primarily affects compliance, financial crime, and banking practices. Regulated firms need to verify that their sanctions screening and client onboarding procedures have been updated to reflect the current HRTC list and that any existing client relationships connected to jurisdictions that have moved on or off the list are being treated correctly. Law firms advising regulated clients will be issuing compliance gap analysis memos and updating AML policies. A trainee working in a financial crime or banking compliance team would assist with drafting a regulatory notification summary of the changes, updating client-facing onboarding documentation, and cross-checking the firm's existing matter list for any connections to newly listed or delisted jurisdictions.
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“How should a UK bank's compliance team respond to a new FATF plenary decision that adds a jurisdiction to the high-risk third countries list, and what are the legal consequences of failing to update AML procedures in time?”
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