Commission Updates AML/CFT High-Risk List
In June 2025, the Commission updated its list of high-risk jurisdictions with strategic deficiencies in their anti-money laundering and counter-terrorist financing regimes, requiring EU entities to apply enhanced vigilance in transactions involving them. Ten jurisdictions were added: Algeria, Angola, Côte d’Ivoire, Kenya, Laos, Lebanon, Monaco, Namibia, Nepal, and Venezuela. Eight were removed: Barbados, Gibraltar, Jamaica, Panama, the Philippines, Senegal, Uganda, and the United Arab Emirates. The revised list takes the legal form of a delegated regulation and enters into force after scrutiny by the European Parliament and the Council (for the scrutiny period see Art. 290(2)(b) TFEU).
The legal basis is (yet) Art. 9(1),(2) of the fourth AML Directive (Directive (EU) 2015/849), according to which the Commission is responsible for identifying high-risk third countries with strategic deficiencies in their anti-money laundering and counter-financing of terrorism (AML/CFT) regimes. As set out in Art. 18a, this Directive requires banks and other financial institutions to exercise heightened vigilance when dealing with such high-risk third countries. The identification and listing of third countries whose AML/CFT regimes have strategic deficiencies aims to protect the integrity of the EU's financial system and internal market, reinforce internal security, and promote sustainable development. The list is regularly updated (for previous updates →eucrim 2/2023, 144). The EU list of high-risk countries specifically takes into account the FATF list of "Jurisdictions under Increased Monitoring". This list is also regularly updated.