Anti-money laundering

New third countries added to black list

On 13 February 2019, the EU Commission updated its list of countries with “strategic deficiencies in their anti-money laundering and counter-terrorist financing frameworks”. There are now a total of 23 countries named on the list, up from the previous figure of 16.

The countries and territories concerned are: Afghanistan, American Samoa, the Bahamas, Botswana, Democratic People’s Republic of Korea, Ethiopia, Ghana, Guam, Iran, Iraq, Libya, Nigeria, Pakistan, Panama, Puerto Rico, Samoa, Saudi Arabia, Sri Lanka, Syria, Trinidad and Tobago, Tunisia, US Virgin Islands, and Yemen.

The new list follows an assessment by the EU Commission designed to identify high-risk third countries under the 4th and 5th anti-money laundering directives, with the 5th Directive having reinforced the assessment method by adding stricter risk criteria.

The list was adopted by the Commission in the form of a Delegated Regulation, which has still to be approved by the European Parliament and Council, before coming into force in the EU Member States.

Under the Monetary Agreement of 29 November 2011 between the European Union and Monaco, the Principality committed to adopting measures equivalent to those of the EU texts listed in Annex B of the Agreement. These include Delegated Regulation (EU) n° 2016/1675 of 14 July 2016 supplementing Directive (EU) 2015/849 by identifying high-risk third countries with strategic deficiencies.

Annex B will therefore need to be updated as soon as the new Delegated Regulation is adopted.

In the meantime, reporting institutions are advised to begin updating their procedures right away, in order to apply the more stringent vigilance measures for transactions or customers connected to the 23 jurisdictions listed above.


The picture of Stephan Pastor
Stephan Pastor
The picture of Anne Fleur Grillot
Anne-Fleur Grillot
Senior Associate