Under the anti-money laundering obligations set forth in the Anti-Money Laundering Act (AMLA), obligated entities are required to apply enhanced due diligence measures when conducting business with certain countries. A distinction between so-called “Grey List” countries and “Black List” countries is made.
Grey List
The so-called Grey List includes countries where the Financial Action Task Force (FATF) has identified strategic deficiencies in the fight against money laundering and terrorist financing, but which have committed to improving their systems.
Particular caution is advised when conducting business or engaging in transactions with individuals or companies from these countries. As a general rule, enhanced due diligence is required, in particular:
- Obtaining additional information about the contracting party,
- more rigorous verification of the source of funds,
- closer monitoring of the business relationship,
- Documentation of the risk assessment.
Inclusion of a country on the Grey List does not automatically mean that business relations are prohibited; rather, it indicates an increased risk.
Black List
The Black List includes countries with significant strategic shortcomings in the area of anti-money laundering that do not cooperate sufficiently with international organizations or fail to implement adequate corrective measures.
Business relationships with individuals or companies from these countries are considered particularly high-risk. In such cases, particularly stringent measures are often required. In certain cases, business relationships may even have to be refused or may be subject to reporting requirements.
These measures include, in particular:
- comprehensive identity and background checks,
- Approval by management,
- increased monitoring of all transactions,
- if necessary, filing a suspicious activity report in accordance with § 43 of the Money Laundering Act.
Note
The lists are updated regularly by the FATF and at the European level. Businesses and obligated entities should therefore ensure that they always use the most current versions of the country lists.
On our website, we provide ongoing updates on relevant changes and their impact on anti-money laundering compliance obligations.
Use this map to find out if your chosen country is considered a high-risk country. Please click on your chosen country for more information.
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