Ministerial Decree no. 2025-219 of April 30, 2025, published in the Journal de Monaco on May 09, 2025, updates the list of HRSTs.
Main changes to the list of High-Risk States or Territories (HRST):
The list now includes 38 States. 2 States have been added:
Afghanistan
Algeria
Angola
Barbados
Bulgaria
Burkina Faso
Cameroon
Democratic Republic of the Congo
Croatia
Gibraltar
Haiti
Islamic Republic of Iran
Ivory Coast
Jamaica
Kenya
Democratic People’s Republic of Korea
Lao People’s Democratic Republic
Lebanon
Mali
Mozambique
Myanmar
Namibia
Nepal
Nigeria
Uganda
Panama
Philippines
Senegal
South Africa
South Sudan
Syria
Tanzania
Republic of Trinidad and Tobago
United Arab Emirates
Vanuatu
Venezuela
Vietnam
Yemen
As a reminder, the obligations relating to ETHRs are as follows:
When a transaction involves a counterparty with links to an ETHR, a special examination report must be drawn up and kept (article 14 of law no. 1.362 as amended);
When a business relationship or transaction involves an ETHR, enhanced due diligence measures must be put in place (cf. article 14-2 of law no. 1.362 as amended).
If you have any questions, please do not hesitate to contact us.