What Has Changed?

The Financial Action Task Force (FATF) concluded its October 2025 plenary meeting with significant adjustments to its high-risk country designations, delivering important implications for law firms operating under the Money Laundering Regulations 2017. The most notable developments include the removal of South Africa and Nigeria from the FATF monitoring list

The delisting signals that both countries have substantially completed their respective action plans and demonstrated sufficient progress in strengthening their anti-money laundering and countering the financing of terrorism (AML/CFT) frameworks.

The jurisdictional changes enable firms to review existing client due diligence, and firms with clients and matters arising from these jurisdictions can decide whether enhanced due diligence is still required. If an individual remains high risk due to other factors, they must also remain on the high risk register.

Therefore, firms must avoid blanket downgrades and should maintain individualised risk assessments that consider all relevant factors.

Firms should update their Firm Wide Risk Assessment to reflect South Africa and Nigeria’s improved FATF status. If you are part of our Regulation Service at the Regulation and Compliance Office (RACO), we will update your Firm Wide Risk Assessment in line with these changes.

What Is the Updated FATF Monitoring List?

The updated FATF monitoring list included the following countries:

Algeria, Angola, Bolivia, Bulgaria, Cameroon, Côte d’Ivoire, Democratic Republic of the Congo, Haiti, Kenya, Lao PDR, Lebanon, Monaco, Namibia, Nepal, South Sudan, Syria, Venezuela, Vietnam, Virgin Islands (UK), Yemen

Regulatory Framework Under MLRs 2017

Regulation 33(1)(b) of the MLRs establishes clear obligations for all relevant persons when dealing with high-risk third countries (HRTCs). The regulation requires enhanced customer due diligence measures and enhanced ongoing monitoring for any customer relationship or transaction involving a person established in an HRTC.

A person is considered “established” in a jurisdiction if they are incorporated there or conduct their principal place of business there (for legal entities) or are resident there (for individuals). This definition captures a broad range of business relationships that may trigger enhanced due diligence requirements.

Compliance and Regulation Support Services

All firms must demonstrate and uphold high standards in their AML systems and processes, as well as in their management and supervision. This also involves outlining how the firm operates, including the conduct of staff in accordance with established policies, controls, and procedures.

At the Regulation & Compliance Office, we can offer a number of outsourced support solutions, including:

• Regulation & Compliance Service – Our Regulation and Compliance Service, Inc. Risk Management Assessment and AML Risk, provides a cost-effective but essential solution for law firms to ensure they achieve a compliant environment. We work with firms of all types, from sole practitioners through to partnerships, Limited Companies and ABSs. We recognise that it is essential to recognise how a firm implements compliance to tailor the solution to each firm’s working practices. This is why our service is completely bespoke to each firm we work with.
• Regulation & Compliance Outsource Guidance and Support Service – This service provides law firms with a cost-effective outsourced solution which sees the compliance managers of RACO take on the day-to-day guidance and support expected to be provided by COLPs, COFAs, Data Compliance Officers, MLROs and MLCOs. This addition to the Regulation and Compliance Service—including Risk Management and AML Risk—relieves the Compliance Officers from most of the day-to-day burden of keeping up with regulatory requirements and ensures staff have access to compliance and risk advice when they need it.
• Due Diligence & Risk Assessment Service – At the Regulation and Compliance Office (RACO), we provide law firms with a seamless, outsourced solution for Client Due Diligence (CDD) and Risk Assessments. Our Due Diligence and Risk Assessment Service has been designed to enable law firms to focus on the provision of the legal services while we collate the necessary documentation for Due Diligence, Enhanced Due Diligence (where needed), and completion of the Client and Matter Risk Assessment, which must be completed on all matters in scope of the Money Laundering Regulations 2017.
• AML Training Courses – Our Typical AML Training Includes:
  • AML Training for ALL staff to meet the firm’s obligation to provide annual training.
  • One-to-one training for the MLRO and MLCO on their obligations and requirements.

Contact Us

To ask any questions about the Regulation and Compliance Office and how we can support your Law Firm, please call us on 0203 985 8550, complete the online enquiry form, or email us info@regulationandcomplianceoffice.co.uk