We reported in a previous update on the FCA’s publication, following a Freedom of Information Act request, of a list of countries considered to be “high risk” for financial crime purposes, which was used by its supervisory teams on visits to regulated firms.

The list has now been removed from the FCA’s website, reportedly after the Cayman government objected to inclusion of the Cayman Islands on the list. This highlights the political sensitivity of such lists, and the difficulties for firms in assessing jurisdictional risk, if even the regulator (reportedly) has difficulty in doing so in a transparent yet defensible way.