The updated document specifically highlights:
- Clearer delineation of country risk within the wider context of CDD and enhanced due diligence EDD;
- Criminal indicators, political and regulatory factors which should be considered when developing a methodology to evaluate country risk;
- Sanctions considerations and their impact in the context of AML/CTF country risk;
- The need for a strong governance enabling an unbiased approach towards country risk; and
- Practical guidance combined with clear roles & responsibilities for financial institutions.
Firms should consult the updated FAQs and continue to remain up to date with their requirements relating to geographical risk.