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High-risk countries

The risk-based approach provided for in Article 7 of the Law of 18 September 2017 (the AML Law) includes the adaptation of vigilance measures, that shall be applied on the obliged entities, to the identified ML/TF risks. If the obliged entities find that the ML/TF risk is high, they must increase vigilance.

Relations with natural persons or legal entities established in third countries showing a high-risk, shall automatically be considered as being a high risk in respect of which the obliged entities shall impose increased vigilance measures (Article 38 of the AML Law).

Third countries showing a high risk are defined in Article 5 of the AML Law as countries considered as having a high geographical risk by:

  1. The FATF
  2. The European Commission
  3. The National Security Council, the Ministerial Committee for the co-ordination of the fight against the laundering of money of illegal origin or the obliged entities themselves.

FATF list of countries showing a high ML/FT risk for the international financial system

FATF Recommendation 19 calls on countries to apply a high level of vigilance in respect of business relationships and transactions with natural persons, legal entities and financial institutions established in countries that are identified by FATF as countries having strategic deficiencies in the fight against anti-money laundering and the financing of terrorism or the proliferation of weapons of mass destruction.

Three times a year the FATF publishes two lists of countries that have strategic AML/CFT deficiencies:


This so-called ‘blacklist’ contains countries in respect of which the FATF calls on its members to apply effective countermeasures in order to protect the international financial system against the ML/TF risks emanating from these countries. Examples of such countermeasures can be found in the Interpretive Note to Recommendation 19 (p. 86).

The list currently includes:

  1. Myanmar
  2. North Korea
  3. Iran


This so-called ‘greylist’ contains countries where strategic AML/CFT deficiencies have been identified and which have committed themselves at political level to implement an action plan in order to overcome these deficiencies.

This list currently includes:

  1. Albania
  2. Barbados
  3. Burkina Faso
  4. Cameroon
  5. Cayman Islands
  6. Croatia
  7. Democratic Republic of Congo
  8. Gibraltar
  9. Haiti
  10. Jamaica
  11. Jordan
  12. Mali
  13. Mozambique
  14. Nigeria
  15. Panama
  16. Philippines
  17. Senegal
  18. South Afrika
  19. South Sudan
  20. Syria
  21. Tanzania
  22. Turkey
  23. Uganda
  24. United Arab Emirates
  25. Vietnam
  26. Yemen

EU list of countries showing a high ML/FT risk for the EU financial system

Article 9 of directive 2015/849 empowers the European Commission to identify third countries that show strategic deficiencies in their national AML/CFT regulations, which poses a serious threat for the EU financial system („high-risk third countries”). Increased vigilance must be applied in respect of relationships with customers established in those countries.

For the first time, on the basis of this authorisation, the Commission established a list of third countries involved, attached as an annex to the Delegated Regulation (EU) 2016/1675 of 14 July 2016. This list is updated regularly and was last modified on by the Delegated Regulation 2023/410 of 19 december 2022.

The EU list is an autonomous list composed according to its own methodology. This means that the EU list differs from the FATF list.

The EU list currently includes:

  1. Afghanistan
  2. Barbados
  3. Burkina Faso
  4. Cambodia
  5. Cayman Islands
  6. Democratic Republic of Congo
  7. Gibraltar
  8. Haiti
  9. Iran
  10. Jamaica
  11. Jordan
  12. Mali
  13. Morocco
  14. Mozambique
  15. Myanmar
  16. North Korea
  17. Panama
  18. Philippines
  19. Senegal
  20. South Sudan
  21. Syria
  22. Tanzania
  23. Trinidad and Tobago
  24. Uganda
  25. United Arab Emirates
  26. Vanuatu
  27. Yemen

Absence of a Belgian list

Article 54 of the AML Law provides for the possibility at Belgian level to take countermeasures against countries that - within the framework of national risk assessment - are identified as countries with inadequate regulations or with traditions that constitute an obstacle to the fight against money laundering or the financing of terrorism.

To the present day no use has yet been made of the above-mentioned possibility.

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