On 8 July 2025, the European Commission adopted a Delegated Regulation that introduces a review clause requiring an independent assessment of countries that may pose a threat to the EU financial system. The regulation is set to enter into force on 10 September 2025, twenty days after its publication in the Official Journal of the European Union on 21 August 2025. This update builds on a previous regulation adopted on 10 June 2025, which amended the list of high-risk third countries outlined in Commission Delegated Regulation 2016/1675.
Importantly, the new clause empowers the European Commission to evaluate countries that are not publicly identified by the Financial Action Task Force (FATF) but may still jeopardize the integrity of the EU financial system. This is especially relevant for countries whose FATF membership has been suspended due to serious violations of core anti-money laundering and counter-terrorism financing standards.
Once in force, the European Commission will be expected to complete this autonomous assessment by 31 December 2025, in line with Article 9 of Directive 2015/849, which focuses on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing.
This development underlines the EU’s commitment to proactively safeguarding its financial system from emerging risks beyond the scope of existing international listings.
For more information or support, please contact us
