FIRMCY Insights

Geography comes first

Regulator commentary · all insights
Geography comes first

Geographic risk comes before everything else in an AML file: is the client, the owner, or the money connected to a listed jurisdiction?

Four public lists drive the answer for EU and Cyprus obliged entities: the FATF call-for-action list (3 jurisdictions), the FATF increased-monitoring list (22), the EU high-risk third-country list (25) and the EU's Annex I of non-cooperative tax jurisdictions (10). The firm.cy country-risk A–Z holds the current status of 213 jurisdictions across all four, updated after every FATF plenary and EU amendment — so the country-risk line in a client file can cite where the jurisdiction stands today, not where it stood when the template was written.

Checking a list answers one question; a compliant file still needs the rest — sanctions, PEP and adverse-media screening on the parties themselves, with the findings written into an audit-ready report.

Browse the A–Z: firm.cy/aml-country

Not legal advice. Verify against the primary source before acting. List membership counts as of the August 2026 synchronisation.

Published 11 August 2026 · Regulator commentary
Drafted with AI assistance. Reviewed, edited and approved before publication by a named person at Ioannou & Sharpe LLC, who takes editorial responsibility for its content. Approved by the firm's editorial reviewer.

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Not legal advice. FIRMCY publishes this analysis for general informational purposes; verify against the primary sources before acting.