Real-time monitoring of customers and transactions against the EU list of third countries with a high risk of money laundering

"360 Screenings monitors the EU list of high-risk third countries and flags business relationships and transactions that require enhanced due diligence"

What is the EU list of third countries with a high risk of money laundering?

Pursuant to Art. 29 para. 1 AMLR6 (here), The European Commission (EC) is empowered to identify non-EU high‑risk countries ("high-risk third countries") having significant strategic deficiencies in their national regime on anti-money laundering and countering the financing of terrorism (AML/CFT regimes).

When does the EU publish updates to its country lists?

The European Commission updates the list multiple times a year, often aligned with FATF's listing schedule (here).

Which section within the European Commission is responsible for the listing of high-risk countries?

The Commission department responsible for EU policy on financial services is the Directorate-General for Financial Stability, Financial Services, and Capital Markets Union (DG FISMA).

What actions need to be taken when an EU high-risk country is involved?

Obliged entities such as financial institutions situated in the EU must carefully examine "business relationships or occasional transactions" involving such high-risk third countries and apply enhanced due diligence (EDD) measures to customers and transaction with a nexus to such countries.

Most importantly, the EU list of high-risk countries may go beyond the FATF grey and blacklists, which means that parallel surveillance is required. The impact of these two lists on (i) the risk classification of a financial institution's entire customer base and (ii) its cross-border payment traffic should not be underestimated.

EU Anti-Money Laundering Regulation (AMLR6)

Currently, obliged entities are only required to observe enhanced due diligence in presence of business relationships domiciled in a high-risk third country.

The new EU Anti-Money Laundering Regulation (AMLR6), which will apply directly to all EU Member States from July 2027 without further implementing acts, will bring about a significant change with regard to high-risk third countries. In accordance with AMLR6, the mere involvement of a high-risk country is sufficient to trigger enhanced due diligence obligations.

Such an involvement may exist, for example, if the funds of a transaction are located in a high-risk third country, even though the contracting parties or beneficial owners are not domiciled in that third country.

Which countries are currently included in the EU list of third countries with a high risk of money laundering?

• Afghanistan
• Algeria
• Angola
• Bolivia
• British Virgin Islands
• Cameroon
• Congo (Democratic Republic)
• Côte d'Ivoire
• Haiti
• Iran
• Kenya
• Laos
• Lebanon
• Mali
• Monaco
• Myanmar
• Namibia
• Nepal
• North Korea
• Russia
• South Sudan
• Syria
• Trinidad and Tobago
• Vanuatu
• Venezuela
• Viet Nam
• Yemen
  

EU - Third countries with a high risk of money laundering (27)