EU: List of high-risk countries and jurisdictions for money laundering and terrorism financing amended once again
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On 3 and 4 December 2025, the European Commission adopted two new delegated regulations - (EU) 2026/46 and (EU) 2026/83 (“Regulations”) – that amend the list of third countries with strategic deficiencies in their Anti-Money Laundering ("AML") and Counter-Terrorism Financing ("CTF") systems. The Regulations amend the Delegated Regulation (EU) 2016/1675 that initially specified high risk third countries.
What is changing?
The following countries are to be added to the list: Bolivia, the British Virgin Islands, the Russian Federation.
The following countries will be removed from the list: Burkina Faso, Mali, Mozambique, Nigeria, South Africa, Tanzania.
Starting from 29 January 2026, the list will involve 26 high risk countries, more specifically:
- Afghanistan
- Algeria
- Angola
- Bolivia
- British Virgin Islands
- Cameroon
- Côte d’Ivoire
- Democratic People's Republic of Korea
- Democratic Republic of the Congo
- Haiti
- Iran
- Kenya
- Laos
- Lebanon
- Monaco
- Myanmar
- Namibia
- Nepal
- Russian Federation
- South Sudan
- Syria
- Trinidad and Tobago
- Vanuatu
- Venezuela
- Vietnam
- Yemen
The Regulations have been published in the European Official Journal and will enter into force on 29 January 2026.
What does it mean for obliged entities?
Under Directive (EU) 2015/849 (AMLD 4), the European Commission shall identify such third countries (i.e. non-EU Member States) having strategic deficiencies in their AML/CTF who may pose significant threats to the EU financial system. Obliged entities need to apply enhanced customer due diligence when business relationships or transactions involve high-risk third countries, enhanced transaction monitoring, additional documentation requirements etc.
