Countries with an increased risk
Obliged entities under the FM-GwG are required to apply enhanced customer due diligence for natural or legal persons resident or established in third countries identified as high risk countries. This covers both customers who have their registered office or place of residence in such a third country as well as business relationship or (occasional) transactions that have a linkage to such a third country.
Which countries fall within this scope of application is determined for the entire EEA by a Delegated Regulation. Please consult the Annex to Delegated Regulation (EU) 2016/1675 in its respective current version.
Furthermore obliged entities must also take geographical risk into account accordingly both with regard to their customer risk assessment as well as their own entity’s risk assessment.
The FMA therefore draws attention to the particular risk in the following FATF documents:
The sanctions lists fall within the scope of competences of the Oesterreichische Nationalbank (OeNB). General information about the topic of financial sanctions can be found here. Information can be found here about the OeNB Regulations in relation to the Exchange Control Act (in German only) (DevG; Devisengesetz) and “sanctions relating to Iran“.