Ministerial Order no. 2022-662 of December 2, 2022, published in the Journal de Monaco on December 9, 2022, updates the list of states and territories whose anti-money laundering, anti-terrorist financing or anti-corruption measures are strategically deficient.
This publication amends Ministerial Order no. 2021-703 of November 8, 2021.
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 includes 30 countries (including 3 new countries in green) :
| Afghanistan | Nicaragua |
| Albania | Uganda |
| Barbados | Pakistan |
| Burkina Faso | Panama |
| Cambodia | Philippines |
| United Arab Emirates | Democratic Republic of Congo |
| Gibraltar | Senegal |
| Haiti | South Soudan |
| Cayman Islands | Syria |
| Jamaica | Tanzania |
| Jordan | Trinidad and Tobago |
| Mali | Turkey |
| Marocco | Vanuatu |
| Mozambique | Yemen |
| Myanmar/Burma | Zimbabwe |
These changes follow the latest developments in the FATF watch list.
Please contact our team if you have any questions.