Changes to EU list of high-risk third countries with strategic AML/CTF framework deficiencies

The European Commission (EC) has announced that it has listed Russia as a high-risk country with strategic deficiencies in its anti-money laundering and counter-terrorist financing frameworks (AML/CFT) pursuant to the EU's directive on anti-money laundering and terrorist financing (AMLD IV). This follows Delegated Regulation (EU) 2025/1393, adopted in July, which committed the EC to conclude a review of third countries not listed by the Financial Action Task Force (FATF), but whose membership is suspended. This included Russia which, following a technical assessment, the EC concludes meets the criteria to be designated as a high-risk third country. The EC has therefore adopted a delegated regulation adding Russia to its list of high-risk jurisdictions presenting strategic deficiencies in their national AML/CFT regimes. On the following day, 4 December, the EC made a further announcement that it has updated its list of high-risk jurisdictions presenting strategic deficiencies in their national AML/CFT regimes following the decisions taken at the FATF and its list of 'Jurisdictions under Increased Monitoring' ('grey list'), following the plenaries of June and October 2025. The EU has adopted a further delegated regulation under AMLD IV adding new third-country jurisdictions (Bolivia and the British Virgin Islands) to the list of jurisdictions with strategic deficiencies and delisting a number of others (Burkina Faso, Mali, Mozambique, Nigeria, South Africa and Tanzania). The delegated regulations will enter into force after scrutiny and non-objection of the European Parliament and the Council within a period of one month (which can be extended by a further month). EU entities covered by the EU's AML framework are required to apply enhanced vigilance in transactions involving such high-risk jurisdictions.

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