Appendix I - Countries That are Presenting Higher Risks

Summary

This is Appendix I to the GFSC's AML/CFT Handbook, a reference list of countries and territories identified by external sources (FATF, OECD, US State Department, UK HM Treasury, and non-governmental bodies such as Transparency International) as presenting higher money laundering, terrorist financing or proliferation financing risk. It is effective from 7 July 2026 and is intended to help firms assess country risk when considering a business relationship or occasional transaction.

• Purpose: Lists countries flagged by intergovernmental, government and think-tank sources across eleven risk indicators (FATF monitoring, OECD tax standards, drug trafficking, governance indicators, human trafficking, terrorism sponsorship, sanctions, bribery risk, corruption perceptions, fragile states, and terrorism impact).
• Not automatic high risk: Inclusion of a country on Appendix I does not automatically mean a related business relationship or transaction is high risk; firms retain discretion to apply a risk based assessment as set out elsewhere in the Handbook (Section 3.4).
• Distinction from Appendix H: Countries subject to FATF calls for countermeasures, which require mandatory enhanced due diligence (ECDD), are listed separately in Appendix H, not in this Appendix I.

The document itself is a data table for reference rather than a standalone set of new rules; it supports the risk based approach obligations already imposed on firms under the wider AML/CFT Handbook.

Key obligations

• Firms must take the country/territory risk information in Appendix I into account, alongside other factors, when conducting risk based assessments of business relationships or occasional transactions under Section 3.4 of the Handbook
• Firms must apply enhanced customer due diligence (ECDD) only to countries listed in Appendix H (not Appendix I), where FATF has called for countermeasures

Applies to

financial services firms subject to the GFSC AML/CFT Handbook

Deadlines

• 7 July 2026: Effective date of this version of Appendix I (list of higher risk countries and territories)