Appendix D2 – Countries and territories identified as presenting higher risks

Last revised: 24 October 2025

Appendix D2 of the of the AML/CFT/CPF Handbook provides details of countries, territories and areas that have been identified by reliable and independent sources as presenting a higher risk of:

• Money laundering
• Financing of terrorism and
• Financing of proliferation of weapons of mass destruction.

Source 14 is created by the national TF Operational Working Group, including representatives of the JFSC and other competent authorities, applying the methodology explained here: Guidance on countries with higher risk of facilitating terrorist financing (gov.je)

Countries, territories and areas listed under Source 1 (FATF black list) and Source 2 (FATF grey list)  are also to be treated as being non-compliant with FATF Recommendations for the purpose of Article 17A of the Money Laundering (Jersey) Order 2008.

Source 6 will only capture financial sanctions regimes that relate to a country, territory or area, i.e. it will not capture thematic sanctions regimes. For a full list of financial sanctions regimes applicable in Jersey see Sanctions by country and category.

Countries, territories and areas covered by each Source may not be consistent when one Source is compared with another Source. Equally, the information may be incomplete or out of date.

We do not accept responsibility for the findings and conclusions of these sources.

Relevant persons are expected to exercise judgement in relation to how they interpret and use the Sources and should reach and document their own consideration and conclusions on risk. See Sections 3, 6 and 7 of the AML/CFT/CPF Handbook for further guidance.

The risk indicators (red flags) are populated from the following sources:

• The Higher Risk/Money Laundering-list (Column B) is based on Sources 1, 2, 3, 4, 7, 8, 9, 10 and 11.
• The Higher Risk/Financing of Terrorism-list (Column C) is based on Sources 1, 2, 3, 4, 5, 10, 13 and 14.
• The Higher Risk/Financial Sanctions-list (Column D) is based on Source 6 only
• The Higher Risk/Financing of Proliferation of Weapons of Mass Destruction-list (Column E) is based on Sources 1 and 12.

We undertake periodic and ad hoc reviews and/or updates of the Sources as follows:

1. Three times per year based on FATF/FSRB Plenary publications listing concerning:
   
   • High risk jurisdictions subject to a Call for Actions (Appendix D1 and equal to the data provided in Source 1 of Appendix D2).
   • Higher risk jurisdictions under Increased Monitoring (Source 2 of Appendix D2).
2. Annually when the information in the other Sources of Appendix D2 is refreshed, ordinarily in Quarter 1 (Sources 3-5 and 7-13).
3. Anytime when Jersey legislation imposes or lifts restrictive measures related to countries or territories, known as geographical sanctions regimes (Source 6 of Appendix D2)
4. Anytime when the national TF Operational Working Group updates the list (Source 14).

Changes in Jersey sanctions regimes targeting certain activities or goods worldwide (terrorism, cyber-attacks, human rights, corruption, chemical weapons etc.) are irrelevant to the updating of Appendix D2, since they do not target jurisdictions.

Sources

All relevant persons are also encouraged to independently verify the Appendix D2 Sources by following the links below