2025 – African countries on the EU blacklist: legal and commercial implications
The European Union (EU) has recently updated its list of high-risk third-country jurisdictions, identifying several African nations as having strategic deficiencies in their anti-money laundering (AML) and counter-terrorism financing (CFT) frameworks. This development carries significant legal and commercial consequences for businesses and financial institutions operating in or transacting with these countries.
Newly blacklisted African countries
As of June 2025, the EU has added the following African countries to its high-risk list:
- Algeria
- Angola
- Côte d’Ivoire
- Kenya
- Namibia
These countries join others previously listed, such as Burkina Faso, Nigeria, South Africa, and Tanzania, which remain under enhanced scrutiny .
Rationale and process
The EU’s blacklist is designed to protect the integrity of its financial system by identifying jurisdictions with inadequate AML/CFT regimes. The process is closely aligned with the recommendations and monitoring activities of the Financial Action Task Force (FATF), the global standard-setter in this domain. The European Commission conducts a thorough technical assessment, considering FATF findings, bilateral dialogues, and on-site evaluations before updating the list. The legal basis for these updates is Article 9 of the 4th Anti-Money Laundering Directive (AMLD IV), which mandates regular reviews and updates to the list .
Practical Consequences
Inclusion on the EU blacklist triggers a series of enhanced due diligence requirements for EU-based financial institutions when dealing with entities or transactions linked to these countries. This means:
- More rigorous customer checks and transaction monitoring
- Increased compliance costs and administrative burdens
- Potential delays or restrictions in cross-border financial flows
- Heightened reputational risk for businesses with significant exposure to blacklisted jurisdictions
For the affected countries, the blacklisting can deter foreign investment, complicate access to international financial markets, and place additional pressure on governments to reform their regulatory frameworks in line with international standards.
Pathways to removal
Countries can be removed from the blacklist by demonstrating substantial progress in addressing the identified deficiencies. Recent examples include Senegal and Uganda, which were delisted following significant improvements in their AML/CFT regimes. The process typically involves the implementation of comprehensive action plans, ongoing engagement with FATF and EU authorities, and successful on-site assessments.
Strategic considerations for businesses
For companies operating in or with these jurisdictions, it is essential to:
- Review and strengthen internal compliance programmes
- Monitor regulatory developments and engage with local partners to ensure alignment with evolving standards
- Prepare for increased scrutiny from EU counterparties and financial institutions
Conclusion
The EU’s updated blacklist underscores the growing importance of robust AML/CFT compliance in cross-border business, particularly for those active in Francophone Africa. Navigating these regulatory challenges requires both legal expertise and a proactive approach to risk management.
At John W Ffooks & Co, we often provide legal counselling to financial institutions and multinational companies operating in high-risk jurisdictions and would be pleased to assist you in managing the complexities of compliance and cross-border transactions in this evolving landscape.
Sources
- https://www.fatf-gafi.org/ , Jurisdictions under Increased Monitoring - 13 June 2025
- https://www.theafricareport.com/, Five African countries added to the EU’s money‑laundering blacklist
- https://finance.ec.europa.eu/, Commission updates list of high-risk countries to strengthen international fight against financial crime
- https://finance.ec.europa.eu/, Anti-money laundering and countering the financing of terrorism at international level