March 22, 2023

Volume XIII, Number 81

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March 22, 2023

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AML: UK Government Publishes Money Laundering and Terrorist Financing (Amendment) (High-Risk Countries) Regulations 2021

On March 25, the UK Government published the Money Laundering and Terrorist Financing (Amendment) (High-Risk Countries) Regulations 2021 (SI 2021/392) on its website together with an explanatory memorandum (the Regulations).

The Regulations amend regulation 33(3)(a) of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (SI 2017/692) (MLRs 2017).

Schedule 3ZA, which sets out a list of high-risk third countries, will be inserted into the MLRs 2017. The Regulations will change the definition of a “high-risk third country” from a country that was defined by a European Commission delegated act to a country specified in the new Schedule 3ZA, and they make a subsequent amendment to regulation 39(4).

The Regulations also repeal the retained EU law version of Commission Delegated Regulation (EU) 2016/1675, which provides a list of high-risk third countries recognized by the European Commission. This list will be superseded by the new list in Schedule 3ZA.

The Regulations go into effect on March 26.

Amendment Regulations

Explanatory Memorandum

©2023 Katten Muchin Rosenman LLPNational Law Review, Volume XI, Number 92
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About this Author

Carolyn H. Jackson, International Attorney, Katten Muchin law firm
Partner

Carolyn Jackson is a partner in Katten Muchin Rosenman UK LLP and is a Registered Foreign Lawyer. She provides US financial regulatory legal advice to a broad range of market participants, including commercial banks, investment banks, investment managers, broker-dealers, electronic trading platforms, clearinghouses, trade associations and over-the-counter derivatives service providers.

Carolyn guides clients in the structuring and offering of complex securities, commodities and derivatives transactions and in complying with US securities and commodities laws...

+44 0 20 7776 7625
Nathaniel Lalone, Katten Muchin Law Firm, Financial Institutions Attorney
Senior Associate

Nathaniel Lalone, a partner at Katten Muchin Rosenman UK LLP, has a broad range of experience in the regulation of financial products and financial markets, and frequently provides regulatory and compliance advice to trading venues, clearing houses and buy-side firms active in the over-the-counter (OTC) derivatives, futures and securities markets. He is actively involved in advising clients on the implementation of MiFID 2 and MiFIR in the European Union as well as the international reach of US financial services regulation. He also has significant experience with structuring...

+44 0 20 7776 7629
Neil Robson, private equity fund managers counselor, Katten Law Firm, London
Partner

Neil Robson, a regulatory and compliance partner with Katten Muchin Rosenman LLP, focuses his practice on counseling hedge and private equity fund managers and other investment advisers on operational, regulatory and compliance issues. He regularly addresses Financial Conduct Authority (FCA) and EU authorization and compliance under both the EU Alternative Investment Fund Managers Directive (AIFM Directive) and MiFID, cross-border issues in the financial services sector, market abuse, anti-money laundering and regulatory capital requirements, formations and buyouts of...

44-0-20-7776-7666