What countries are high risk for money laundering?
High-risk countries are those with weak anti-money laundering systems, high corruption, or links to terrorism financing. When dealing with clients or funds from these countries, you must apply Enhanced Due Diligence (EDD). Two major lists identify these countries: the FATF lists (black and grey) and the Basel AML Index.
The Financial Action Task Force (FATF) maintains a "black list" of countries with the most serious strategic deficiencies. These are subject to a "Call for Action" with countermeasures:
- Democratic People's Republic of Korea (North Korea)
- Iran
- Myanmar (Burma)
For these countries: Apply enhanced due diligence and consider countermeasures.
FATF Grey List - Countries Under Increased Monitoring (as of October 2025)
The "grey list" includes countries actively working to address strategic deficiencies in their AML/CFT systems:
- Algeria
- Angola
- Bolivia
- Bulgaria
- Burkina Faso
- Cameroon
- Côte d'Ivoire
- Democratic Republic of the Congo
- Haiti
- Kenya
- Lao PDR
- Lebanon
- Monaco
- Mozambique
- Namibia
- Nepal
- Nigeria
- South Africa
- South Sudan
- Syria
- Venezuela
- Vietnam
- Virgin Islands (UK)
- Yemen
For these countries: Apply risk-based Enhanced Due Diligence. The level depends on your specific risk assessment - don't automatically refuse business, but increase scrutiny.
Good news: Countries can and do get removed from these lists when they improve their systems. In 2025, Burkina Faso, Mozambique, Nigeria, and South Africa were removed from the grey list after completing their action plans.
Basel AML Index - Broader Risk Assessment
The Basel AML Index ranks 177 countries based on money laundering risk using 17 indicators including corruption levels, financial transparency, and regulatory quality.
Highest Risk Countries (Basel AML Index 2025):
- Myanmar
- Haiti
- Democratic Republic of the Congo
- Chad
- Equatorial Guinea
- Angola
- Republic of the Congo
- Gabon
- Central African Republic
- Guinea-Bissau
Lowest Risk Countries (Basel AML Index 2025):
- Finland
- Iceland
- San Marino
- Denmark
- Estonia
What This Means for Your Business
When clients or transactions involve high-risk countries, you must:
1. Apply Enhanced Due Diligence
- Verify source of wealth (how they accumulated assets overall)
- Verify source of funds (where this specific money comes from)
- Understand the purpose and nature of the relationship
- Conduct more frequent reviews
- Obtain senior management approval
2. Understand the Connection
Not every transaction involving these countries is high-risk. Consider:
- Is the client from that country or just transacting with it?
- Is it a one-off transaction or ongoing relationship?
- Does the business relationship make commercial sense?
- Are there legitimate reasons for the connection?
Example: An Australian mining company doing business in the DRC is different from an individual with no obvious connection trying to route money through the DRC.
How easyAML Helps
easyAML automatically flags when clients or transactions involve high-risk countries and guides you through the Enhanced Due Diligence process. The platform:
- Checks client addresses against FATF and Basel lists
- Alerts you to high-risk jurisdictions
- Provides guidance on what additional checks to perform
- Documents your EDD process for AUSTRAC compliance
High-risk countries require enhanced due diligence, not automatic refusal. Understand why the country is high-risk, assess whether that risk applies to your specific client and transaction, and document your decision-making process.
The lists change regularly - countries can improve (and get removed) or deteriorate (and get added). easyAML will keep you up to date with high risk or prohibited countries.
What To Do Next
- Use easyAML's screening - Automatically flag high-risk countries
- Apply EDD when needed - Not all connections to these countries are problematic
- Document your assessment - Record why you proceeded or declined
Remember: High-risk countries require enhanced scrutiny, not discrimination. Apply proportionate, risk-based due diligence and document your reasoning.