European Commission list of high-risk third countries

Article 9.2 of the Fourth EU Money Laundering Directive (Fourth Directive) allows the European Commission (EC) to identify 'high-risk third countries'.

These countries are identified as having strategic deficiencies in their national anti-money laundering and counter-financing of terrorism regimes that pose significant threats to the EU’s financial system.

You must apply enhanced due diligence (EDD) measures in any transaction or business relationship with a person established in a high-risk third country.

For more guidance on appropriate EDD measures, see our guide to customer due diligence and the Legal Sector Affinity Group’s Anti-money laundering guidance.

High-risk third countries

The EU’s 5th Money Laundering Directive broadened the criteria for the EC in assessing high-risk third countries.

The EC has recently made some changes to the list that will take effect later in 2020.

Twenty-eight countries have currently been identified as high-risk third countries for money laundering and terrorist financing. They are:

  • Afghanistan
  • The Bahamas*
  • Barbados*
  • Botswana*
  • Cambodia*
  • Democratic People's Republic of Korea (DPRK) – has repeatedly failed to address deficiencies
  • Ghana*
  • Iran – seeking technical assistance in the implementation of the FATF Action Plan
  • Iraq
  • Jamaica*
  • Mauritius*
  • Mongolia*
  • Myanmar*
  • Nicaragua*
  • Pakistan
  • Panama*
  • Syria
  • Trinidad and Tobago
  • Uganda
  • Vanuatu
  • Yemen
  • Zimbabwe*

*These countries will be added to the list from 1 October 2020 

View the EC’s original list of high-risk third countries (July 2016)

The list was later amended in four delegate regulations:

May 2020

October 2017

December 2017

July 2018