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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. Cambodia
  5. Cayman Islands
  6. Democratic Republic of Congo
  7. Gibraltar
  8. Haiti
  9. Jamaica
  10. Jordan
  11. Mali
  12. Morocco
  13. Mozambique
  14. Panama
  15. Philippines
  16. Senegal
  17. South Sudan
  18. Syria
  19. Tanzania
  20. Turkey
  21. Uganda
  22. United Arab Emirates
  23. 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 2022/229 of 7 January 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. Haiti
  7. Iran
  8. Jamaica
  9. Jordan
  10. Mali
  11. Morocco
  12. Myanmar
  13. Nicaragua
  14. North Korea
  15. Pakistan
  16. Panama
  17. Philippines
  18. Senegal
  19. South Sudan
  20. Syria
  21. Trinidad and Tobago
  22. Uganda
  23. Vanuatu
  24. Yemen
  25. Zimbabwe

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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