What changes, who is affected, and how to act in response to the UIFAND alert
On 13 February 2026, the Unitat d’Intel·ligència Financera d’Andorra (UIFAND) published Technical Communiqué CT-02/2026, through which it updates the list of countries and jurisdictions classified as high risk for the purposes of Prevention of Money Laundering and Terrorist Financing (PBC/FT), in line with the standards of the Financial Action Task Force (GAFI).
This is not a minor adjustment. The update reshapes the approach to country risk and raises the required due diligence standard, with a direct operational impact on natural and legal persons that maintain —commercial, financial or corporate— links with the jurisdictions included on the list.
In practice, this means that any economic operator with exposure to these jurisdictions included on the list must immediately review its internal compliance procedures.
1. Legal framework: how the system works
UIFAND determines, by way of a Technical Communiqué, which jurisdictions present an elevated level of risk. This determination is not merely declaratory, but rather triggers specific legal obligations for all obliged entities.
There are three operational pillars to be aware of:
a) Country risk classification
High-risk jurisdictions are those designated as such by UIFAND, taking into account the international standards of the GAFI and the applicable European framework. Inclusion on the list is binding.
b) Enhanced due diligence obligation
Where there is any link to a high-risk jurisdiction, obliged entities must apply enhanced due diligence measures. It is not a recommendation, but a requirement, and non-compliance results in sanctions.
c) Maximum-intensity countermeasures
In jurisdictions assessed as presenting a “very high” risk, the regime is intensified, as any commercial relationship or financial transaction is prohibited, as well as any link with natural or legal persons from those territories. It is an absolute closure.
2. Updated classification by risk levels following the UIFAND alert
a) Jurisdictions with very high risk
| Jurisdiction | Operational effect |
| Democratic People’s Republic of Korea (North Korea) | Absolute prohibition of any commercial relationship or financial transaction, as well as of any link with natural persons or legal persons from these territories. |
| Iran | |
| Myanmar |
b) Jurisdictions with high risk or strategic deficiencies
The following jurisdictions present strategic deficiencies in matters of PBC/FT and require the application of enhanced due diligence measures:
| Algeria | Monaco |
| Angola | Namibia |
| Bolivia | Nepal |
| Bulgaria | Papua New Guinea |
| Cameroon | Lao People’s Democratic Republic |
| Ivory Coast | Democratic Republic of the Congo |
| Haiti | Syria |
| British Virgin Islands | South Sudan |
| Kenya | Venezuela |
| Kuwait | Vietnam |
| Lebanon | Yemen |
Operational effect: obliged entities must incorporate CT-02/2026 into their internal PBC/FT procedures and keep evidence of its application in order to demonstrate compliance in the event of requests from UIFAND.
3. Enhanced due diligence: what it entails in practice
Where country risk requires it, the standard of verification, consistency and traceability must be raised substantially. Enhanced due diligence is not an additional formality; it is the mechanism that enables the obliged entity to demonstrate that it has understood the risk and acted accordingly.
In concrete terms, it implies:
a) Thorough identification and verification
Of the client and the ultimate beneficial owner, including the control structure, with special attention to multi-layer or cross-border structures.
b) Enhanced analysis of the purpose of the business relationship
Full understanding of the nature, purpose and economic rationale of the transactions.
c) Evidence of the origin of funds and wealth
Robust and consistent documentation evidencing the lawful origin, with particular rigor when the transaction involves high-risk jurisdictions.
d) Evidentiary file and traceability
It is not enough to have reviewed. For the purposes of any potential request, it is essential to be able to evidence what was reviewed, why, and what evidence supports each decision.
Our approach to the UIFAND alert
At Carlota Pastora Business Law Firm & Wealth Planning we work on the premise: that regulatory compliance should not be an obstacle, but a competitive advantage.
Our team anticipates friction points that can block transactions, supports the implementation of PBC/FT procedures and turns regulatory risk management into an operational, financial and reputational lever. If you need a specific analysis of your situation or to review your internal procedures in light of CT-02/2026, contact us.
