2015 Directive of the European Parliament and of the Council on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC. According to Article 18(3) of the Directive, when assessing the risks of money laundering and terrorist financing, Member States and obliged entities shall take into account at least the factors of potentially higher-risk situations set out in Annex III. Sanctions is included as a “geographical risk factor” in this Annex III, which contains a non-exhaustive list of factors and types of evidence of potentially higher risk: “countries subject to sanctions, embargos or similar measures issued by, for example, the Union or the United Nations.”

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