Due Diligence Requirementsk and international Sanctions Law

I. Due Diligence Requirements

1. Adjustment of List A regarding countries with strategic deficiencies

On 4 December 2025, the European Commission adopted Delegated Regulations (EU) 2026/46 and 2026/83 amending Delegated Regulation (EU) 2016/1675 concerning the identification of high-risk third countries with strategic deficiencies. These regulations will enter into force in the EU on 29 January 2026.

Delegated Regulation 2026/46 adds Russia to the EU list of high-risk third countries. Delegated Regulation 2026/83 adds Bolivia and the British Virgin Islands to this list (both already included in List A due to their FATF listing) and removes Burkina Faso, Mali, Mozambique, Nigeria, South Africa, and Tanzania.

According to current information, the incorporation of these EU list adjustments into the FMA List A is planned for 6 February 2026. Once the EEA adoption has taken place, the FMA will publish the updated list on its website and issue a notification.

To allow obliged entities sufficient time to implement these changes after publication of the updated List A, the FMA considers it sufficient if the necessary adjustments in the respective systems are completed by 6 March 2026 (Should there be delays in the EEA adoption, the FMA will provide further information.)

The CPL again emphasizes that, for countries with strategic deficiencies, even a single involvement2 in the overall client relationship is sufficient to require classification as “high risk.” For other geographical risks under List A, however, the scope of persons concerned is narrower and the relevant points of contact are exhaustively defined.

II. International Sanctions Law

UK Sanctions List (UKSL): Unified UK Designations List

As of 28 January 2026, the United Kingdom has transitioned to a single, official designations list: the UK Sanctions List (UKSL) is now the sole source for all UK sanctions designations. The previous OFSI Consolidated List of Asset Freeze Targets was simultaneously discontinued and will no longer be updated (it remains available only for reference). This also applies to the OFSI search tool: it now only covers designations up to the cut-off date. Current designations are available exclusively via the UKSL and the new UKSL Search.