BaFin Circular 13/2025 on High-Risk Countries

Countries classified as high-risk states continue to include North Korea, Iran, and Myanmar. These countries exhibit severe deficiencies in their anti-money laundering and counter-terrorist financing systems.

With regard to these countries, the following measures must be taken in accordance with BaFin requirements:

North Korea

Due to the acute threat situation, the FATF calls on states to take the following measures:

• Terminate correspondent banking relationships with banks from North Korea;
• Close all subsidiaries or branches of North Korean banks within their jurisdictions;
• Restrict business relationships and financial transactions with persons from North Korea.

Specific legal consequences and measures by BaFin regarding North Korea

In addition to the enhanced due diligence obligations set out in Section 15 (5) GwG, obliged entities must comply with further specific measures. These include, in particular, increased requirements for identifying beneficial owners, who must undergo full identification in accordance with Sections 11 (4) no. 1 and 2 in conjunction with Section 12 (1) and (2) GwG. German credit institutions are also required to verify whether their correspondent banks in third countries maintain accounts for North Korean companies or individuals and whether comparable enhanced due diligence obligations are applied. All additional checks must be documented in an audit-proof manner. Furthermore, under BaFin’s general administrative act of 13 May 2020, all business relationships and transactions involving North Korea are subject to mandatory reporting.

Iran

With regard to Iran, the FATF calls on states in its statement “High-Risk Jurisdictions subject to a Call for Action” of 24 October 2025 to implement effective countermeasures, including:

• Refusing the establishment of subsidiaries, branches, or representative offices of Iranian credit and financial institutions;
• Prohibiting credit and financial institutions from establishing branches or representative offices in Iran.

Specific legal consequences and measures by BaFin

BaFin also requires the application of enhanced due diligence obligations pursuant to Section 15 (5) GwG for transactions involving Iran. According to the general administrative act of 13 May 2020, business relationships and transactions with Iran must be reported to BaFin. In addition, branches and subsidiaries of Iranian financial institutions are subject to enhanced supervision.

Myanmar

For all transactions involving Myanmar, at least the enhanced due diligence measures set out in Section 15 (5) GwG must be applied. At the same time, it should be ensured that financial flows for humanitarian aid or legitimate non-profit activities are not disrupted.

Countries under FATF "Increased Monitoring"

For countries that are included on the FATF grey list but not listed in the EU Delegated Regulation, no immediate additional obligations apply to obliged entities. However, the situation in these countries must be appropriately considered within the general country risk assessment.

Based on the FATF report “Jurisdictions under Increased Monitoring” of 24 October 2025, this includes 20 countries:

1. Algeria
2. Angola
3. Bolivia
4. British Virgin Islands
5. Bulgaria
6. Democratic Republic of the Congo
7. Lao People’s Democratic Republic
8. Côte d’Ivoire
9. Haiti
10. Yemen
11. Cameroon
12. Kenya
13. Lebanon
14. Monaco
15. Namibia
16. Nepal
17. South Sudan
18. Syria
19. Venezuela
20. Vietnam
    

The FATF emphasizes that these countries exhibit deficiencies but have already made progress.

For a full overview and further details, the circular is available on the BaFin website: Circular 13/2025 (GW).