High-risk third country

A high-risk third country is a country outside the EU that the European Commission has listed for strategic weaknesses in its anti-money laundering and counter-terrorist financing regime. Banks, EMIs and other obliged entities must apply enhanced due diligence to business relationships and transactions involving these countries.

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How a country gets on the list

The Commission adopts the list as a delegated regulation under the EU AML Directive. It updates the list mostly in line with the Financial Action Task Force, which publishes a "black list" (call for action) and a "grey list" (increased monitoring) after each plenary. The Commission can also list countries on its own assessment. From 10 July 2027 the power moves to Article 29 of the AML Regulation, with the same purpose.
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The current EU list

The list below applies from 29 January 2026, under Delegated Regulations (EU) 2026/46 and 2026/83 amending Regulation 2016/1675.
RegionCountries
AfricaAlgeria, Angola, Cameroon, Côte d'Ivoire, Democratic Republic of the Congo, Kenya, Namibia, South Sudan
AmericasBolivia, British Virgin Islands, Haiti, Trinidad and Tobago, Venezuela
Asia and PacificAfghanistan, Laos, Myanmar, Nepal, North Korea, Vanuatu, Vietnam
Europe and Middle EastIran, Lebanon, Monaco, Russia, Syria, Yemen
The 2026 update added Bolivia, the British Virgin Islands and Russia, and removed Burkina Faso, Mali, Mozambique, Nigeria, South Africa and Tanzania.
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What enhanced due diligence means in practice

When a client, its beneficial owners or its payments involve a listed country, the provider has to do more than standard KYB. Typically that means more information on the business and its owners, evidence of source of funds and source of wealth, the reason for the relationship or transaction, sign-off by senior management and closer transaction monitoring afterwards. Expect more questions and a longer review, not an automatic refusal.
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EU list vs FATF lists

The EU list follows FATF closely but isn't identical: timing differs, and the Commission sometimes adds countries FATF hasn't listed. Providers in the EU must apply the EU list. Many also screen against the FATF lists and their own jurisdiction risk ratings.
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FAQ

No. The list triggers extra checks, not a ban. Sanctions are a separate regime and can prohibit dealings outright.

Usually a few times a year, after FATF plenaries in February, June and October.

Monaco joined the FATF grey list in 2024 and the EU followed. Listing reflects AML framework weaknesses, not development level.

No. The UK keeps its own list in its money laundering regulations.
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Last reviewed October 21, 2026Disclaimer
This publication is provided for general information purposes and does not constitute legal, tax, or other professional advice from Narvi Payments Oy Ab or its affiliates, and it is not intended as a substitute for obtaining advice from a financial advisor or any other professional.
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