Posted on 2025-06-11
EU Updates Its List of High-Risk Third Countries for Money Laundering
The European Union (EU) has updated its list of high-risk third countries with strategic deficiencies in their anti-money laundering and counter-terrorism financing (AML/CFT) regimes. This update takes into account the work of the Financial Action Task Force (FATF), which regularly publishes a list of “jurisdictions under increased monitoring.” While there is considerable overlap between the FATF and EU lists, they are not identical: FATF does not have the authority to impose sanctions, whereas the European Commission (EC), under the EU’s Fourth Anti-Money Laundering Directive (4AMLD), has the power to require Member States to apply enhanced customer due diligence measures when dealing with high-risk third countries.
In its latest update, the EU has removed eight jurisdictions from its high-risk list due to significant improvements in their AML/CFT frameworks. These jurisdictions are: Barbados, Gibraltar, Jamaica, Panama, the Philippines, Senegal, Uganda, and the United Arab Emirates (UAE).
The revision is enacted through a delegated regulation, which automatically enters into force one month after publication, unless the European Parliament or the Council of the EU raise objections. This is not merely procedural: in March 2024, the European Parliament previously blocked an attempt to delist Gibraltar, Panama, and the UAE due to concerns about the circumvention of sanctions.
However, the European Commission now maintains that these jurisdictions have made sufficient progress to justify their removal. Gibraltar has strengthened its supervision of both financial and non-financial sectors and improved its asset confiscation systems. Panama has demonstrated that its authorities effectively respond to foreign requests for company and trust ownership information. The UAE has enhanced judicial and law enforcement cooperation with other states, particularly EU Member States.
Turkey remains a unique case. Although the Commission considers its AML regime to have “strategic deficiencies,” it has refrained from applying punitive measures, citing the ongoing accession negotiations between Turkey and the EU, which include efforts to address these issues.
Conversely, the EU has added 11 jurisdictions to its high-risk list: Algeria, Angola, Côte d'Ivoire, Kenya, Laos, Lebanon, Monaco, Namibia, Nepal, Venezuela, and Côte d'Ivoire (noted again, possibly a duplication in the original source). With these additions, the EU’s list now comprises 27 jurisdictions considered high-risk for money laundering and terrorist financing.
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