BaFin has issued Circular 03/2026 (GW) on March 30, 2026, detailing countries identified as high-risk due to deficiencies in their anti-money laundering (AML) and counter-terrorism financing (CFT) systems. These identified deficiencies can potentially endanger the stability of the international financial system. This circular serves as an update and guidance for financial institutions operating within the EU.

Financial institutions, including banks, insurers, and asset managers, must review the identified high-risk countries and assess their potential impact on their operations. While the circular itself does not impose new direct obligations, it informs risk assessments and due diligence processes. Compliance officers should ensure their AML/CFT policies and procedures align with the information provided in the circular to mitigate risks associated with transactions involving entities or individuals from these jurisdictions.