EU List of High-Risk Third Countries (December 2025)
The EU List of High-Risk Third Countries identifies non-EU jurisdictions that have strategic deficiencies in their anti-money laundering (AML) and counter-terrorist financing (CFT) regimes. These deficiencies pose significant risks to the integrity of the EU financial system and therefore trigger mandatory enhanced due diligence (EDD) obligations for obliged entities under EU AML law.
The list is adopted and regularly updated by the European Commission in the form of delegated regulations, based on:
- FATF “Jurisdictions under Increased Monitoring” (grey list)
- Autonomous EU risk assessments and technical reviews
- Mutual evaluations and technical compliance findings
- Structured dialogues and monitoring of high-level political commitments
Latest Update: December 2025
In December 2025, the European Commission adopted two Delegated Regulations amending Delegated Regulation (EU) 2016/1675, resulting in a material expansion and partial reduction of the EU high-risk country list.
The December update reflects:
- FATF Plenary decisions of June and October 2025, and
- a stand-alone EU assessment of countries not currently listed by FATF but posing heightened AML/CFT risks.
Both Delegated Regulations are not yet in force and will become legally binding only after publication in the Official Journal and completion of the scrutiny period by the European Parliament and the Council.
Newly Added to the EU List (December 2025)
Countries under FATF Increased Monitoring
The following jurisdictions were added to the EU high-risk list due to ongoing AML/CFT deficiencies and active FATF action plans, combined with high-level political commitments to remediate these shortcomings:
- Bolivia
- British Virgin Islands
These jurisdictions correspond to the FATF “Jurisdictions under Increased Monitoring” category and are subject to mandatory enhanced due diligence under EU law.
Country with Strategic AML/CFT Deficiencies
In addition, the Commission added the following country following an autonomous EU technical assessment:
- Russia
Russia is designated as a high-risk third country with strategic AML/CFT deficiencies, based on:
- a dedicated review mandated by Delegated Regulation (EU) 2025/1393, and
- an assessment using information from public sources, Member States’ competent authorities, and the European External Action Service.
Unlike FATF grey-listed jurisdictions, no reference is made to a high-level political commitment or FATF action plan, placing Russia in a qualitatively more severe risk category under EU AML law.
Removed from the EU List (December 2025)
The following countries were removed from the EU high-risk list after demonstrating sufficient progress in addressing AML/CFT deficiencies and implementing agreed action plans:
- Burkina Faso
- Mali
- Mozambique
- Nigeria
- South Africa
- Tanzania
Their removal means that automatic country-based EDD under Article 9 AMLD IV no longer applies. However, institutions must continue to apply risk-based measures where justified by customer, product, or transaction risk.
What Does Listing Mean for Financial Institutions?
If a country appears on the EU list, obliged entities (including banks, payment institutions, crypto-asset service providers, auditors, and legal professionals) must:
- Apply enhanced customer due diligence (EDD) in accordance with
Article 18 and Article 18a of Directive (EU) 2015/849 - Perform enhanced transaction monitoring
- Obtain and assess source of funds and source of wealth
- Conduct deeper analysis of beneficial ownership and control structures
- Apply senior management approval and consider
risk-based restrictions or termination of business relationships
Institutions must update their:
- country-risk classifications,
- business-wide risk assessments,
- KYC/EDD procedures,
- transaction-monitoring rules, and
- audit trails
once the delegated regulations enter into force.
Legal Basis
The EU list of high-risk third countries is based on:
- Directive (EU) 2015/849 (4th Anti-Money Laundering Directive)
- Delegated Regulation (EU) 2016/1675, as amended
- Delegated Regulation (EU) 2025/1393 (EU review of suspended FATF members)
- The European Commission’s methodology for identifying high-risk third countries
Downloads
Sources:
https://ec.europa.eu/commission/presscorner/detail/en/ip_25_2910