China AML

Most China files don't get the country-risk answer wrong. They get it once, and never revisit the date.

Four separate lists decide it — FATF's call-for-action and increased-monitoring lists, the EU's high-risk third-country list, and Annex I of the EU's non-cooperative tax jurisdictions. A file that records one and not the others isn't wrong so much as unfinished, and it shows the moment a client, a beneficial owner or a payment corridor touches China. The lists move several times a year, so an undated entry tells the auditor nothing about what you knew when.

This week: pull the China files and put a date beside the country-risk line.

Read: https://firm.cy/aml-country/china

Not legal advice. Verify against the primary source before acting.

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