EU: List of high-risk countries for money laundering and terrorism financing amended
Written By
Partner
Germany
As partner in our Finance & Financial Regulation Group in Frankfurt, I advise our national and international clients on banking regulatory issues and finance law.
Senior Associate
Sweden
I am a senior associate in the Finance & Financial Regulation Group in Stockholm. My passion lies in fintech, innovation, financial regulation, data protection and AI, as well as combining my knowledge in these areas to provide high quality cross-sector advice to our clients.
On 10 June 2025, the European Commission adopted a new Delegated Regulation (EU) 2025/1184 in relation to third countries which have strategic deficiencies in their AML/CFT regimes (“Regulation”). The Regulation amends the Delegated Regulation (EU) 2016/1675 that initially specified the high risk third countries.
A number of countries were removed from the previous list: Barbados, Gibraltar, Jamaica, Panama, the Philippines, Senegal, Uganda and the United Arab Emirates.
Several countries were added to the list: Algeria, Angola, Ivory Coast, Kenya, Laos, Lebanon, Monaco, Namibia, Nepal and Venezuela. The current list, therefore, now entails 27 high risk countries.
Under Directive (EU) 2015/849 (AMLD 4), the European Commission shall identify such third countries (i.e. non-EU Member States) having strategic deficiencies in their AML/CFT. Those countries may pose significant threats to the EU financial system. Obliged entities under AML laws need to apply enhanced customer due diligence when business relationships or transactions involves high-risk third countries. For example, such entities must obtain additional information on the customer and on the beneficial owner(s), the intended nature of the business relationship, the source of funds and source of wealth of the customer and of the beneficial owner(s) and the reasons for the intended or performed transactions. Further, approval of senior management is necessary for establishing or continuing the business relationship. During the business relationship, the obliged entity needs to conduct enhanced monitoring by increasing the number and timing of controls.
The removal of countries like UAE will significantly foster businesses between EU Member States and the UAE.
The change took into account the recommendation and work done by the Financial Action task Force (FATF). The Regulation has now been published in the European Official Journal and will enter into force on 5 August 2025.
