Federal Circular No. 2/2023 On the Lawyers’ Obligations in Relation to the Updated List of High-Risk Countries and Countries Under Increased Monitoring and the Countermeasures to Be Applied

With reference to the National Anti-Money Laundering and Combating the Financing of Terrorism and Financing of Illegal Organisations Committee Decision No. 1 (9/2021) on the Update of the List of High-Risk Countries and Countries under Increased Monitoring and Determining the Countermeasures to be applied by financial institutions and designated non-financial businesses and professions;

And with reference to Article 22 of Cabinet Decision No. 10/2019 on the Implementing Regulation of Federal Decree-Law No. 20/2018 on Anti-Money Laundering and Combating the Financing of Terrorism and the Financing of Illegal Organisations, stipulating the following:

  1. Financial institutions and designated non-financial businesses and professions shall apply enhanced due diligence measures proportionate to the level of risk arising from business relationships or transactions with a physical or legal person from a high-risk country.

  2. Financial institutions and designated non-financial businesses and professions shall implement the measures specified by the Committee in relation to high-risk countries.