What has happened to the UK Financial Conduct Authority's leaked anti-money-laundering blacklist of 95 countries? It seems to have vanished.

The Cayman Island government protested loudly when it discovered that its jurisdiction was on the UK Financial Conduct Authority's leaked list of 'high money-laundering risk' jurisdictions. The FCA claimed that it based its list on the prevalence in various countries of 'laundrogenic' laws, company structures, politics, sectoral risk and many other things. The recently revised Joint Money-Laundering Steering Group guidelines, which still await approval from HM Treasury, contain a URL that guides the reader to the list for future reference. Now the controversy has died a gentle death, with the deletion of all mention of the list from the FCA website.

The list originally came to light, Compliance Matters understands, because a journalist at Thomson Reuters persuaded a source at the FCA to admit to the list's existence and yield it up for publication. It was reported that both the regulator's authorisations department and its financial crime team had been using it on supervisory visits, apparently without forewarning firms that they ought to be applying it. The FCA's reaction was to decide to brazen it out and publish the list on its website, coupled with a blank refusal to explain in any detail the risk weightings and other factors in its evaluation (if any) of each of the world's countries. 95 states made it onto the list; the other 101 did not.

As criticism from law firms and offshore centres mounted and it seemed as though ridicule was just around the corner, the regulator decided to withdraw the list.

The 95 countries on the list were: Afghanistan, Algeria, Angola, Argentina, Azerbaijan, Bahrain, Bangladesh, Belarus, Benin, Bolivia, Bosnia and Herzegovina, Brazil, Bulgaria, Burundi, Cambodia, Cayman Islands, China, Colombia, Republic of the Congo, Democratic Republic of Congo, Cuba, Djibouti, Dominican Republic, Ecuador, Egypt, Equatorial Guinea, Eritrea, Ethiopia, Fiji, Gabon, Guatemala, Guinea, Guinea-Bissau, Haiti, Honduras, India, Indonesia, Iran, Iraq, Israel, Ivory Coast (Cote d’Ivoire), Jamaica, Kazakhstan, Kenya, Korea (North), Kosovo, Kuwait, Kyrgyzstan, Laos, Latvia, Lebanon, Liberia, Libya, Malaysia, Mali, Mexico, Montenegro, Morocco, Myanmar, Nauru, Nepal, Nicaragua, Niger, Nigeria, Pakistan, Palestine, Panama, Romania, Russia, Saudi Arabia, Serbia, Seychelles, Sierra Leone, Somalia, South Africa, Sri Lanka, Sudan (North), Sudan (South), Suriname, Swaziland, Syria, Tajikistan, Tanzania, Thailand, Tunisia, Turkey, Turkmenistan, UAE, Ukraine, Uzbekistan, Vatican City, Venezuela, Yemen, Zambia and Zimbabwe.

Thomson Reuters stated that the list (which, as we have seen, contained half the jurisdictions and most of the population of the world) “set out the countries that firms should pay the highest possible regard to in terms of AML compliance.” Despite this dire-sounding judgment against the greater part of mankind, the tally failed to include Aruba, the British Virgin Islands, Curaçao, Gibraltar, Ireland, Hong Kong, Malaysia, Malta, Singapore and Vietnam. Great powers such as the US, the UK, France, Germany and Italy (and near-great powers such as Canada and Spain) were also conspicuous by their absence.