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Finance

High risk third countries and the international context content of anti-money laundering and countering the financing of terrorism

The Commission is mandated to identify high-risk third countries having strategic deficiencies in their regime on anti-money laundering and countering the financing of terrorism.

What the EU is doing and why

To effectively combat the global circulation of dirty money, international efforts are needed. The Commission is actively working with international partners for instance through the Financial Action Task Force (FATF), the global standard setter on anti-money laundering and counter terrorism financing. The FATF notably identifies jurisdictions having strategic deficiencies in their regimes to counter money laundering and terrorist financing. The EU’s listing takes into account the recommendations provided by FATF.

The identification of high-risk counties is required in order to protect the EU financial system and the proper functioning of the internal market. The Commission is empowered to identify high-risk third countries which have strategic deficiencies in their anti-money laundering and countering the financing of terrorism frameworks. This reduces the risks that could pose threats to the Union’s financial system.

In line with the Directive (EU) 2018/843 (5th Anti-Money Laundering Directive), gatekeepers, such as banks, are obliged to carefully consider business relationships and transactions involving high-risk third countries through increased checks and control measures defined under Article 18a of the Directive.

Latest version of the list of high-risk third countries

On 12 December 2023, the European Commission adopted a new Delegated Regulation in relation to third countries which have strategic deficiencies in their AML/CFT regimes. The Delegated Regulation amends Delegated Regulation (EU) 2016/1675.

The following jurisdictions are identified as having strategic deficiencies in their AML/CFT regimes:

High-risk third country Date of entry into force
Afghanistan 23 September 2016
Barbados 1 October 2020
Burkina Faso 13 March 2022
Cameroon 18 October 2023
Democratic Republic of the Congo 16 March 2023
Gibraltar 16 March 2023
Haiti 13 March 2022
Iran 23 September 2016
Jamaica 1 October 2020
Mali 13 March 2022
Mozambique 16 March 2023
Myanmar 1 October 2020
Nigeria 16 July 2023
North Korea 23 September 2016
Panama 1 October 2020
Philippines 13 March 2022
Senegal 13 March 2022
South Africa 16 July 2023
South Sudan 13 March 2022
Syria 23 September 2016
Tanzania 16 March 2023
Trinidad and Tobago 6 March 2018
Uganda 23 September 2016
United Arab Emirates 16 March 2023
Vanuatu 23 September 2016
Vietnam 18 October 2023
Yemen 23 September 2016

A consolidated version of the EU list is available (with only measures that already entered into force).

The listing process

Objectives of the list

The objectives of the list can be subdivided into three main goals:

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Protecting the integrity of the Union's financial system and internal market
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Reinforcing internal security
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Promoting sustainable development

What are the steps

The listing process follows a staged approach that can be divided into four parts:

Step1
Priority setting

Pre-assessment to determine the countries to be assessed and identify the level of priority of their assessment, in addition to countries already listed by the Financial Action Task Force.

Step 2
Assessing

Assessment of the relevant 3rd countries’ anti-money laundering and counter-terrorism financing regimes, starting with countries of the highest priority.

Step3
Listing

Listing high-risk third countries that show strategic deficiencies in their anti-money laundering and counter-terrorism financing regimes.

Step 4
Follow-up

Monitor progress of listed countries, continue monitoring of already reviewed countries, and assess additional countries.

Methodology

To ensure a fair and transparent process concerning the identification of third countries, the Commission developed a methodology in 2020. The methodology aims to clarify the measures to identify the high-risk countries based on the faults in their national AML/CTF regimes posing significant threats to the EU’s financial system.

More information on the methodology

Planning of assessment

The Commission carried out a pre-assessment to determine relevant countries to be assessed and the level of priority, in addition to those already listed by the Financial Action Task Force. Countries are considered relevant for the EU financial system in case they meet any of the following non-cumulative criteria

  • a country is identified by the European External Action Service or by Europol as having a systemic impact on the integrity of the EU financial system
  • a country was reviewed as an international offshore financial centres by the International Monetary Fund
  • a country is considered as economically relevant based on the strength of the economic ties with the EU and the magnitude of its financial sector

On this basis, the Commission identified 132 jurisdictions so far that will be further analyzed according to its methodology over the period 2018-2025. The list of 132 countries included in the scope.

With regard to the level of priority

  • the Commission reviews as a matter of priority a first group of 54 jurisdiction (Priority 1 countries). The assessment is an ongoing exercise; hence any country will be reassessed when new relevant information sources become available
  • the other jurisdictions (Priority 2 countries) will be assessed successively until 2025

Evolution of the list

Based on Directive (EU) 2015/849 and the Commission’s power of adopting delegated acts regarding high-risk third countries, the Commission adopted the following delegated acts:

  1. 18 Januray 2024

    Publication of Commission Delegated Regulation (EU) 2024/163 amending the EU list.

  2. 28 September 2023

    Publication of Commission Delegated Regulation (EU) 2023/2070 amending the EU list.

  3. 26 June 2023

    Publication of Commission Delegated Regulation (EU) 2023/1219 amending the EU list.

  4. 24 February 2023

    Publication of Commission Delegated Regulation (EU) 2023/410 amending the EU list.

  5. 21 February 2022

    Publication of Commission Delegated Regulation (EU) 2022/229 amending the EU list.

  6. 7 December 2020

    Publication of Delegated Regulation (EU) 2021/37 amending the EU list.

  7. 7 May 2020

    Revised methodology for identifying high risk third countries

    • FATF lists as a baseline/ and increased synergies with FATF listing process
    • additional countries based on EU own assessment based on increased engagement
    • Enhanced consultation of Member States’ experts

    Publication of Delegated Regulation (EU) amending the EU list

  8. 27 July 2018

    Publication of the Delegated Regulation (EU) 2018/1467 amending the EU list.

  9. 22 June 2018

    First methodology for identifying high risk third countries

    • FATF lists as a baseline
    • additional countries based on EU own assessment
  10. 13 December 2017

    Publication of Delegated Regulation (EU) 2018/212 amending the EU list.

  11. 27 October 2017

    Publication of Delegated Regulation (EU) 2018/105 amending the EU list.

  12. 14 July 2016

    First EU list – based on FATF lists (Delegated Regulation (EU) 1675/2016).

Relevant legislation

FATF
The Commission is a member of the Financial Action Task Force (FATF), the main international body concerned with combating money laundering, the financing of terrorism and other threats to the integrity of the international financial system.

MONEYVAL
The Commission is an observer in Moneyval – the Council of Europe body assessing compliance with AML/CFT standards.

EGMONT
The Commission is an observer at the Egmont Group, an international organisation that provides financial intelligence units with a platform for the secure exchange of expertise and financial intelligence to combat money laundering, terrorist financing, and associated predicate offences.