EU List of High-Risk Third Countries Delegated Regulation (EU) 2016/1675
- Issuing authority
- N/A (triggers EDD obligations)
- Effective date
- Continuously updated; BVI added 16 April 2026
- Scope
- All EU Member States
Key requirements
The EU's official list of countries with weak AML controls. When your customer has links to a listed country, your firm must apply Enhanced Due Diligence (EDD) extra checks. The list is updated regularly: the British Virgin Islands was added on 16 April 2026, meaning BVI-domiciled funds can no longer be marketed in the EU.
Quick Summary
The EU High-Risk Third Countries List identifies countries with weaknesses in their anti-money laundering and counter-terrorist financing systems. If a customer, business, or transaction is linked to one of these countries, firms in the EU must apply Enhanced Due Diligence (EDD).
What is it?
This delegated regulation contains the European Commission's list of high-risk third countries. The list is updated regularly based on international assessments and the EU's own evaluation.
Who does it apply to?
- Banks
- Payment institutions
- Investment firms
- Crypto asset service providers
- Insurance companies
- Lawyers and accountants where AML obligations apply
- Other obliged entities under EU AML legislation
Why does it matter?
Customers connected to a listed country are considered higher risk. Firms must carry out additional checks before establishing or continuing a business relationship.
What should firms do?
- When a customer has links to a listed country, firms may:
- Apply Enhanced Due Diligence.
- Obtain additional information about the customer.
- Understand the source of funds and source of wealth where appropriate.
- Increase ongoing monitoring.
- Document why the relationship is considered acceptable.
AboutAML Breakdown
Being on the EU High-Risk Third Countries List does not mean a country is subject to sanctions or that business is prohibited. Firms must apply additional checks to cutomers from that countries For example, if an investment fund is established in a listed jurisdiction or a customer regularly transfers funds to one of these countries, the firm should assess the increased risk and apply appropriate controls.