25/04/2024

HRST #9 High Risk States and Territories list updated – April 2024

Ministerial Order no. 2023-680 of April 15, 2024, published in Monaco’s Journal de Monaco on April 19, 2024, updates the list of states or territories whose anti-money laundering, terrorist financing or corruption system have strategic deficiencies.

This publication amends Ministerial Order no. 2021-703 of November 8, 2021, amended on November 22, 2023.

As a reminder, the obligations relating to HRST are as follows:

  • When a transaction involves a counterparty with links to an HRST, a special examination report must be drawn up and kept (article 14 of the amended law n°1.362) ;
  • When a business relationship or transaction involves an HRST, enhanced due diligence measures must be put in place (cf. article 14-2 of law no. 1.362 as amended).

The list currently comprises 30 countries. 2 states have been added.

AfghanistanNamibia
South AfricaMyanmar/Burma
BarbadosNigeria
BulgariaUganda
Burkina FasoPanama
CameroonPhilippines
CroatiaSenegal
United Arab EmiratesSouth Sudan
GibraltarSyria
HaitiTanzania
Democratic Republic of the CongoTrinidad and Tobago
JamaicaTurkey
KenyaVanuatu
MaliVietnam
MozambiqueYemen
The United Arab Emirates, Barbados, Gibraltar and Uganda have been removed from the Financial Action Task Force (FATF) grey list. However, Monaco has decided to maintain their ETHR status, as they remain on the European Union list.

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