The EU’s AML blacklist gets its first update of 2026, reshaping due diligence obligations for banks and financial institutions operating across the three continents
January 9, 2026 – The new Delegated Regulation (EU) 2026/83 ammends the Annex to the Commission’s Delegated Regulation (EU) 2016/1675, which identifies third countries with strategic deficiencies in their anti-money laundering and counter-terrorist financing (AML/CFT) regimes. Under the new Anti-Money Laundering Directive (2015/849/EU – 4AMLD), EU-regulated entities are required to apply enhanced due diligence measures to transactions and business relationships involving persons or entities from countries on this list.
The amendment makes two sets of changes, the first of which being the addition of Bolivia and the British Virgin Islands to the list. These additions reflect an unsatisfactory trajectory for both nations after FATF decided back in June and October 2025 to place both nations under enhanced monitoring. While both of these jurisdictions made political commitments at a senior government level to work with FATF and their respective regional bodies (GAFILAT for Bolivia and CFATF for the British Virgin Islands), and the Commission acknowledges in the Regulation that progress has been made, it concludes that strategic deficiencies remain unresolved, making high-risk classification ultimately necessary.
For Bolivia, outstanding work includes deploying risk-based supervision across real estate agents, lawyers, accountants, and dealers in precious stones and metals; ensuring accurate and up-to-date beneficial ownership information; and increasing money laundering investigations and prosecutions. For the British Virgin Islands (a jurisdiction of particular significance given its role as a major offshore corporate and trust services centre) remaining gaps include risk-based supervision of trust and company service providers, virtual asset service providers, and investment firms, as well as improving the quality of suspicious activity reporting and operationalising a new asset management framework.
The second change removes six african nations from the list (Burkina Faso, Mali, Mozambique, Nigeria, South Africa and Tanzania), followins an assesment by FATF that states that the countries have established the legal and regulatory frameworks necessary to address the strategic deficiencies identified in their respective action plans, and no longer warrant enhanced monitoring at an international level.
