20/01/2025

HRST/NCJ #10 High-Risk States or Territories and Non-Cooperative Jurisdictions lists updated

Ministerial Decree no. 2024-756 of December 20, 2024 and Ministerial Decree no. 2025-4 of January 16, 2025, respectively published in the Journal de Monaco on December 27, 2024 and January 17, 2025, update the lists of HRSTs and NCJs.

Main changes to the list of High-Risk States or Territories (HRST):

The list now includes 34 States. 5 States have been added and 1 State has been removed:

  • Afghanistan
  • South Africa
  • Algeria
  • Angola
  • Barbados
  • Bulgaria
  • Burkina Faso
  • Cameroon
  • Croatia
  • United Arab Emirates
  • Gibraltar
  • Haiti
  • Ivory coast
  • Jamaica
  • Kenya
  • Lebanon
  • Mali
  • Mozambique
  • Myanmar/Burma
  • Namibia
  • Nigeria
  • Uganda
  • Panama
  • Philippines
  • Democratic Republic of Congo
  • Senegal
  • South Sudan
  • Syria
  • Tanzania
  • Trinidad and Tobago
  • Turkey
  • 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).

Main changes to the list of Non-Cooperative States or Territories (NCCTs):

The changes concern form only, not substance. The list remains unchanged.

  • Ministerial orders n° 2018-926 and n° 2018-927 of September 28, 2018 are repealed.
  • Iran and North Korea are now listed as NCJs in the same Arrêté Ministériel as HRSTs, in Article 1-1.

As a reminder, the obligations linked to ETNCs are as follows:

  • Transactions and facts concerning natural or legal persons domiciled, registered or established in an ETNC must be reported to the AMSF via the GoAML platform.

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