EU Regulatory Framework: High Risk Third Countries – Delegated Regulation (EU) 2023/2070

On October 4th, 2023, the Cyprus Securities and Exchange Commission (the “CySEC”),  published the Commission Delegate Regulation (EU) 2023/2070 on amending Delegated Regulation (EU) 2016/1675 adding Cameroon and Vietnam to the list of high risk third countries.

The Delegated Regulation (EU) 2023/2070 implements the following change to the Delegated Regulation (EU) 2016/1675:

In the Annex of the Delegated Regulation (EU) 2016/1675, the table under Part I (High-risk third countries which have provided a written high-level political commitment to address the identified deficiencies and have developed an action plan with FATF) is replaced with the following high risk third countries:

  1. Afghanistan
  2. Barbados
  3. Burkina Faso
  4. Cameroon
  5. Cayman Islands
  6. Democratic Republic of the Congo
  7. Gibraltar
  8. Haiti
  9. Jamaica
  10. Jordan
  11. Mali
  12. Mozambique
  13. Myanmar
  14. Nigeria
  15. Panama
  16. Philippines
  17. Senegal
  18. South Africa
  19. South Sudan
  20. Syria
  21. Tanzania
  22. Trinidad and Tobago
  23. Uganda
  24. United Arab Emirates
  25. Vanuatu
  26. Vietnam
  27. Yemen

Further to the above, Regulated Entities are required by Article 64(1) of the Prevention and Suppression of Money Laundering and Terrorist Financing Law of 2007 to 2022 to apply enhanced customer due diligence measures when establishing business relationships or carrying out transactions with natural persons or legal entities established in such high risk third-countries.