The Financial Intelligence Analysis Unit (FIAU) would like to bring to your attention the latest Delegated Acts of the European Union’s (EU) Commission on High-Risk Third Countries, adopted by virtue of Delegated Regulations (EU) 2026/46 of 3 December 2025 and 2026/83 of 4 December 2025, both published in the Official Journal of the European Union (OJEU) on 9 January 2026. As per Article 2 of the same, these Regulations enter into force on the twentieth day following their publication in the OJEU. A copy of these documents has been uploaded to the FIAU’s website under ‘Country Statements’.
In terms of Article 9(4) of Directive (EU) 2015/849, the European Commission is to identify third countries which present strategic deficiencies in their AML/CFT regimes and which pose a significant threat to the EU’s financial system (“high-risk third countries”). The resulting list, which is reviewed and updated from time to time, is then made public through delegated acts.
By virtue of Delegated Regulation (EU) 2026/46, the list of countries in the Annex to Delegated Regulation (EU) 2016/1675 has now been revised. Point IV has been added, listing Russia in a new category of high-risk third countries which are not identified as being subject to calls for action or increased monitoring by the FATF, but whose membership in that international standard-setter is suspended.
Furthermore, by virtue of Delegated Regulation (EU) 2026/83, the list of countries in the Annex to Delegated Regulation (EU) 2016/1675 has also been revised.Bolivia and the British Virgin Islands have been added to the list of high-risk third countries which have provided a written high-level political commitment to address the identified deficiencies and have developed an action plan with the FATF. Burkina Faso, Mali, Mozambique, Nigeria, South Africa and Tanzania have been removed.
A high-risk third country is considered as a non-reputable jurisdiction in line with the definition provided under Regulation 2(1) of the Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR). To comply with Regulations 11(10) and 11(11) of the PMLFTR and Sections 8.1.1 and 8.1.3 of the FIAU Implementing Procedures Part I, where applicable, subject persons should also take note of the EU’s consolidated list of high‑risk third countries.
While the resulting EU lists of high-risk third countries present similarities with the FATF’s own lists, subject persons should be aware that the two are not identical and that a country may be present on one list but not on the other.
Any queries in relation to the above should be addressed to [email protected]