Adjustment of country list A of FMA Guideline 2013/1

On the one hand, the FATF updated its list of "Jurisdictions under Increased Monitoring" ("grey list"). See the most recent publication from February 2025. On the other hand, an updated version (2024) of the "Transparency International Corruption Perceptions Index" was also published.

In addition, the third National Risk Analysis in the area of money laundering, terrorist financing and proliferation financing of the Liechtenstein financial center (NRA III) was published, the annex to which also contains the country lists of countries with an increased risk in connection with terrorist financing and proliferation financing. These two lists are now used for List A instead of the previously used "Global Terrorism Index".

As a result of these updates/adjustments, it can be summarized that

• two countries have been removed from List A (Chile and Malaysia);
• three countries have been added to List A (Qatar, Monaco and Saudi Arabia);

In order to provide the persons subject to due diligence with sufficient time to implement these changes, the FMA considers it sufficient if the necessary adjustments are made in the respective systems by May 15, 2025.

With regard to the "States with strategic deficiencies pursuant to Delegated Regulation (EU) 2024/163 amending Delegated Regulation (EU) 2016/1675" (Article 11a DDA), it should be noted that this has not yet been updated by the European Commission. According to the information currently available to the FMA, this Delegated Regulation is not expected to be updated until the end of 2025.

The currently valid version of List A as well as versions that have expired can be found here.

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