EU takes Panama, Barbados, Gibraltar, the UAE and others off its money-laundering high-risk list
On 10 June 2025 the European Commission adopted Delegated Regulation (EU) 2025/1184, removing Barbados, Gibraltar, Jamaica, Panama, the Philippines, Senegal, Uganda and the United Arab Emirates from the EU list of high-risk third countries for money laundering. It was published on 16 July and took effect on 5 August 2025. EU firms no longer have to apply mandatory enhanced due diligence to them.
Delegated Regulation (EU) 2025/1184 amends Delegated Regulation (EU) 2016/1675, the EU's list of third countries with strategic deficiencies in their anti-money laundering regimes. The removals follow the countries' completion of their FATF action plans.
What changed
- Removed: Barbados, Gibraltar, Jamaica, Panama, the Philippines, Senegal, Uganda and the United Arab Emirates.
- Added: Algeria, Angola, Côte d'Ivoire, Kenya, Laos, Lebanon, Monaco, Namibia, Nepal and Venezuela, all on the FATF's grey list.
- Timing: published in the Official Journal on 16 July 2025, in force on 5 August 2025.
- EU banks, accountants, lawyers and other obliged entities must apply enhanced due diligence to business relationships and transactions involving listed countries. That mandatory step no longer applies to the removed countries, though firms still assess risk case by case.
Background
In March 2024 the European Parliament had blocked an earlier attempt to delist Gibraltar, Panama and the UAE.
Who is affected
Groups with companies in Panama, Barbados, Gibraltar, the UAE or the Philippines that deal with EU banks and service providers.
Sources
- EUR-Lex: Commission Delegated Regulation (EU) 2025/1184
- Regulation Tomorrow: Delegated Regulation updating list of high-risk third countries published in the OJ (July 2025)
- Bird & Bird: EU list of high-risk countries amended (2025)
- KPMG: Panama removed from EU list of high-risk third countries (July 2025)