List of countries subject to restrictions or enhanced reporting requirements in the Kyrgyz Republic
This list is based on the Order No 18 of 7 March 2022 by Kyrgyzstan’s financial intelligence unit. The original Order in Russian can be downloaded here.
The specific meaning of «enhanced due diligence» under Kyrgyz AML law is explained after the below table.
| High-risk country name | Restrictions / reporting requirements | Reason stated by the FIU for inclusion into the list |
|---|---|---|
| Anguilla | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
Domestic offshore zones list |
| Antigua and Barbuda | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
Domestic offshore zones list |
| Aruba | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
Domestic offshore zones list |
| Barbados | Enhanced due diligence | FATF list |
| Belize | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
Domestic offshore zones list |
| Bermuda | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
Domestic offshore zones list |
| British Virgin Islands | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
Domestic offshore zones list |
| Burkina Faso | Enhanced due diligence | FATF list |
| Guinea-Bissau | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
UN Security Council list |
| Gibraltar | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
Domestic offshore zones list |
| State of Libya | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
UN Security Council list |
| Grenada | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
Domestic offshore zones list |
| Islamic Republic of Afghanistan | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
UN Security Council Resolution, FATF public announcement |
| Islamic Republic of Iran | Enhanced due diligence | FATF list |
| Islamic Republic of Mauritania | Enhanced due diligence | List by Basel Institute on Governance |
| Islamic Republic of Pakistan | Enhanced due diligence | FATF list |
| Hashemite Kingdom of Jordan | Enhanced due diligence | FATF list |
| Republic of Yemen | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
FATF list, UN Security Council list |
| Cambodia | Enhanced due diligence | FATF list |
| Principality of Andorra | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
Domestic offshore zones list |
| Principality of Monaco | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
Domestic offshore zones list |
| Democratic People’s Republic of Korea | Business relationship to be declined | FATF list, UN Security Council list |
| Republic of Lebanon | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
UN Security Council list |
| Macao (People`s Republic of China) | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
Domestic offshore zones list |
| Republic of Maldives | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
Domestic offshore zones list |
| Kingdom of Morocco | Enhanced due diligence | FATF list |
| Montserrat | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
Domestic offshore zones list |
| Independent State of Samoa | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
Domestic offshore zones list |
| Niue (New Zealand) | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
Domestic offshore zones list |
| United Arab Emirates | Enhanced due diligence | FATF list |
| Cayman Islands | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
Domestic offshore zones list, FATF list, list by Basel Institute on Governance |
| Cook Islands (New Zealand) | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
Domestic offshore zones list |
| Labuan Islands (Malaysia) | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
Domestic offshore zones list |
| Turks and Caicos Islands | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
Domestic offshore zones list |
| Republic of Albania | Enhanced due diligence | FATF list |
| Republic of Vanuatu | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
Domestic offshore zones list |
| Republic of Haiti | Enhanced due diligence | list by Basel Institute on Governance, FATF list |
| Republic of Iraq | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
UN Security Council list |
| Republic of the Congo | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
list by Basel Institute on Governance, UN Security Council list |
| Republic of Mauritius | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
Domestic offshore zones list |
| Republic of Madagascar | Enhanced due diligence | list by Basel Institute on Governance |
| Republic of Mali | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
list by Basel Institute on Governance, UN Security Council list, domestic offshore zones list |
| Republic of Malta | Enhanced due diligence | FATF list |
| Republic of the Marshall Islands | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
Domestic offshore zones list |
| Republic of Mozambique | Enhanced due diligence | list by Basel Institute on Governance |
| Republic of Nauru | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
Domestic offshore zones list |
| Republic of Nicaragua | Enhanced due diligence | FATF list |
| Republic of Panama | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
FATF list, domestic offshore zones list |
| Republic of Senegal | Enhanced due diligence | list by Basel Institute on Governance, FATF list |
| Republic of Seychelles | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
Domestic offshore zones list |
| Republic of the Union of Myanmar | Enhanced due diligence | list by Basel Institute on Governance, FATF list |
| Republic of the Sudan | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
UN Security Council list |
| Republic of Uganda | Enhanced due diligence | list by Basel Institute on Governance, FATF list |
| Republic of the Philippines | Enhanced due diligence | FATF list |
| Republic of South Sudan | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
UN Security Council list, FATF list |
| Saint Vincent and the Grenadines | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
Domestic offshore zones list |
| Saint Lucia | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
Domestic offshore zones list |
| Syrian Arab Republic | Enhanced due diligence | FATF list |
| Republic of Turkey | Enhanced due diligence | FATF list |
| Somali Republic | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
UN Security Council list |
| Federation of Saint Kitts and Nevis | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
Domestic offshore zones list |
| Central African Republic | 1. Enhanced due diligence 2. Reporting each transaction to the FIU |
UN Security Council list |
| Jamaica | Enhanced due diligence | FATF list |
The meaning of «enhanced due diligence»
Under Kyrgyz law, «enhanced due diligence» must include (Article 21, paragraph 3 of the Anti-money laundering law):
«(1) determine if the client or the client’s beneficiary is a politically exposed person (PEP);
(2) obtain a written approval by the head of the financial organization to initiate or continue business relations with the PEP (if exposed to be a PEP);
(3) determine the source of funds or other property of the PEP;
(4) carry out a continuous and enhanced monitoring of business relations, treating the client as „high risk“.»
However, the application of enhanced measures extends not only to PEP clients, but also to any person resident / registered in the countries in the above table, as they are all classified as «high risk». Each reporting entity must apply the following additional monitoring measures for «high risk» clients (paragraph 12 of Regulations On Client Due Diligence, promulgated by Government Resolution No 606 of 25 December 2018):
«(1) collect additional identifying information and documents in relation to the client from available and trustworthy sources of information and use this information to assess the risk of the client;
(2) collect additional information about the clients and its beneficial owner to deeply understand the risks of possible involvement of the client / beneficiary into criminal activity;
(3) request additional information from the client on the purpose and planned character of the business relations and on the source of funds of the client;
(4) verify the sources of the client’s funds used when establishing relations with the client to ensure that the funds are not gains from criminal activity;
(5) regularly renew identification data of the client and its beneficiary, but at least once a year;
(6) request from the client additional information explaining the purpose and economic reason of the planned or already performed transactions;
(7) obtain a permission to establish or continue business relations with the client from the executive body which manages the current business matters of the financial establishment;
(8) carry out an enhanced monitoring of business relations with the client by daily monitoring of transactions, analyzing information, analyzing and accounting for the destination of the funds, including manually, to single out the signs of suspicious operations and operations having no evident business purpose or obvious legitimate purpose, and report the findings to the Compliance department and the executive body responsible for daily business of the financial establishment;
(9) propose that the transaction planned to be performed without opening a bank account should be performed through a bank account.»
As follows from the above, the measures which are obligatory for clients in the described risk groups place a significant administrative burden on the resources of any financial establishment. The Company reserves the right to refuse accepting clients belonging to the above-described risk groups or apply higher tariffs to compensate for the allocation of the required additional resources to stay compliant with the regulations.