EU’s High‑Risk Third‑Country List: Eight African Nations Under Enhanced AML/CFT Scrutiny
The European Commission periodically updates its register of high‑risk third countries to flag jurisdictions where anti‑money laundering (AML) and counter‑terrorist financing (CFT) frameworks fall short of international standards. The most recent amendment, adopted through Delegated Regulations (EU) 2026/46 and (EU) 2026/83, adds several African states to the list while retaining others that were previously identified. Although the designation does not impose economic sanctions or trade restrictions, it obliges EU‑based banks, payment institutions, and other obliged entities to apply enhanced due diligence when dealing with customers and transactions linked to these countries.
What the high‑risk designation means
Being placed on the EU’s high‑risk list signals that a country exhibits strategic deficiencies in its AML/CFT regime, as assessed against the standards of the Financial Action Task Force (FATF). For financial institutions operating within the European Economic Area, the consequence is a requirement to perform:
- Enhanced customer due diligence (EDD) on natural and legal persons originating from the listed jurisdiction;
- Additional scrutiny of the purpose and nature of transactions;
- More rigorous ongoing monitoring, including the collection of supplementary information such as source of wealth and source of funds.
These measures aim to mitigate the risk that illicit funds enter the EU’s financial system. Importantly, the listing does not ban business activity; rather, it raises the compliance bar for those who choose to engage with the affected markets.
The eight African countries currently on the list
As of the August 2025 update, eight African states are subject to enhanced due diligence obligations. Their effective dates of inclusion vary, reflecting the timeline of the Commission’s assessments.
Algeria
Algeria entered the high‑risk register on 5 August 2025. The Commission cited strategic shortcomings in the country’s AML/CFT legal framework, particularly regarding the supervision of designated non‑financial businesses and professions and the effectiveness of its financial intelligence unit.
Angola
Also added on 5 August 2025, Angola’s inclusion stems from identified gaps in its risk‑based approach to AML/CFT, limited transparency of beneficial ownership information, and insufficient measures to combat the financing of terrorism.
Cameroon
Cameroon has been on the list since 18 October 2023. Persistent concerns include weak supervision of money‑value transfer services, inadequate sanctions screening, and a low rate of suspicious transaction reporting.
Côte d’Ivoire (Ivory Coast)
The latest round of enlargement placed Côte d’Ivoire on the list effective 5 August 2025. The Commission highlighted strategic deficiencies in the country’s legal framework for combating the financing of weapons proliferation and insufficient resources allocated to its AML/CFT supervisory authorities.
Democratic Republic of the Congo
The DRC has faced heightened scrutiny since 16 March 2023. Ongoing issues involve limited implementation of customer due diligence requirements, weak oversight of the informal gold trade, and challenges in prosecuting money‑laundering offences.
Kenya
Kenya, East Africa’s largest economy, was added on 5 August 2025. The Commission’s assessment pointed to gaps in the regulation of virtual asset service providers, insufficient outreach to high‑risk sectors such as real estate, and a need for stronger international cooperation mechanisms.
Namibia
Namibia joined the register on 5 August 2025. Identified deficiencies include a lack of comprehensive risk assessments for non‑profit organisations, limited use of financial intelligence in investigations, and inadequate enforcement of penalties for AML/CFT violations.
South Sudan
South Sudan has been listed the longest among the African entries, with an effective date of 13 March 2022. The country continues to struggle with a fragile institutional environment, minimal AML/CFT legislation, and limited capacity to monitor cross‑border financial flows.
Practical implications for businesses operating in the EU
For companies that engage with customers, suppliers, or partners from these jurisdictions, the high‑risk status translates into several operational adjustments:
- Collecting additional identification documents, such as proof of address and source‑of‑funds declarations.
- Running transactions through enhanced screening tools that check against sanctions lists, adverse media, and politically exposed persons (PEPs) databases.
- Extending the retention period for due diligence records, often beyond the standard five‑year requirement.
- Providing targeted training to front‑line staff on recognizing red flags associated risks in the listed countries.
While these steps can increase processing times and compliance costs, they also help firms avoid potential regulatory penalties, reputational damage, and the risk of facilitating illicit activity.
Pathways to delisting
The EU’s high‑risk list is not static. Countries can be removed once they demonstrate that the identified deficiencies have been adequately addressed. The Commission’s review process considers:
- Evidence of legislative reforms that align AML/CFT laws with FATF recommendations.
- Improvements in the operational effectiveness of supervisory authorities and financial intelligence units.
- Independent assessments, often conducted by the FATF or regional bodies, confirming sustained compliance.
For example, a country that strengthens its beneficial ownership registry, enhances training for supervisors, and shows a measurable increase in suspicious transaction reports may be considered for removal in a subsequent review cycle.
Conclusion
The inclusion of eight African nations on the EU’s high‑risk third‑country list underscores the Union’s commitment to safeguarding its financial system from money‑laundering and terrorist‑financing threats. Although the designation does not prohibit trade, it imposes tangible due‑diligence obligations on EU‑based financial actors. By understanding the specific shortcomings that led to each country’s listing—and monitoring progress toward remediation—businesses can navigate the enhanced compliance landscape while continuing to engage responsibly with these markets.
