On 8 July 2025, the European Commission (Commission) adopted a Delegated Regulation that will insert a review clause into the Delegated Regulation that it adopted on 10 June 2025 which amends the list of high-risk countries laid down in Commission Delegated Regulation (EU) 2016/1675.
Background
On 14 July 2016, the Commission adopted Delegated Regulation (EU) 2016/1675 which identifies a number of high-risk third country jurisdictions with strategic deficiencies in their anti-money laundering and countering the financing of terrorism (AML/CFT) regimes that pose significant threats to the EU’s financial system.
On 10 June 2025, the Commission adopted a Delegated Regulation which amends the list of high-risk third countries laid down in Delegated Regulation (EU) 2016/1675. That amending act followed the recommendations of the international AML/CFT standard setter, the Financial Action Task Force (FATF).
The Commission notes that countries that are not publicly identified as being subject to calls for action or increased monitoring by the FATF might still pose a threat to the integrity of the EU financial system. Where membership of such countries to the FATF is suspended because of gross violations of core principles upon which that standard-setter is built, the threat to the EU financial system is likely to increase.
Review clause
The Delegated Regulation that is being adopted by the Commission inserts into the Delegated Regulation adopted on 10 June 2025 a new Article 1a which states:
“By 31 December 2025, the Commission shall conclude the review of third countries that are not identified as being subject to calls for action or increased monitoring by the FATF, but whose membership in that international standard-setter is suspended, to assess whether to amend the Annex to Delegated Regulation (EU)2016/1675 accordingly.”
Next Steps
The European Parliament and the Council of the EU will scrutinise the Delegated Regulation. If neither object, it will be published in the Official Journal of the European Union and enter into for 20 days after publication.
