On 11th October, an article from Eversheds Sutherland reported on a proposed revised methodology to be used in the creation of a new EU blacklist of ‘high-risk third countries’ with strategic AML/CFT deficiencies.  It examines the proposed revisions to the methodology for a future EU blacklist, and considers whether these are likely to address the EU Council’s earlier criticisms of a previous draft list.

This blog is primarily for my own use, to keep informed and up to date. However, if you would like to say thank you (and perhaps help me get a new, better laptop when I am away…) you can “buy me a coffee” at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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