What changed

B100318/2025

B100316/2025

European Parliament resolution on the Commission delegated regulation of 10 June 2025 amending Delegated Regulation (EU) 2016/1675 to add Algeria, Angola, Côte d’Ivoire, Kenya, Laos, Lebanon, Monaco, Namibia, Nepal and Venezuela to the list of high-risk third countries which have provided a written high-level political commitment to address the identified deficiencies and have developed an action plan with the FATF, and to remove Barbados, Gibraltar, Jamaica, Panama, the Philippines, Senegal, Uganda and the United Arab Emirates from that list

(C(2025)03815 -– 2025/2740(DEA))

– having regard to the Commission delegated regulation (C(2025)03815),

– having regard to Article 290 of the Treaty on the Functioning of the European Union,

– having regard to Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC, in particular Article 9(2) and Article 64(5) thereof,

– having regard to Regulation (EU) 2024/1624 of the European Parliament and of the Council of 31 May 2024 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing,

– having regard to Commission Delegated Regulation (EU) 2016/1675 of 14 July 2016 supplementing Directive (EU) 2015/849 of the European Parliament and of the Council by identifying high-risk third countries with strategic deficiencies, in particular the Annex thereto,

– having regard to its resolution of 23 April 2024 on the Commission delegated regulation of 14 March 2024 amending Delegated Regulation (EU) 2016/1675 as regards adding Kenya and Namibia to the table in point I of the Annex and deleting Barbados, Gibraltar, Panama, Uganda and the United Arab Emirates from that table,

– having regard to Rule 114(3) of its Rules of Procedure,

A. whereas Commission Delegated Regulation (EU) 2016/1675, the Annex thereto and the amending Commission delegated regulation of 14 March 2024 identify high-risk third countries with strategic deficiencies as regards anti-money laundering and countering terrorist financing (AML/CTF), which represent a threat for the Union financial system and for which enhanced customer due diligence measures are to be applied by Union obliged entities under Directive (EU) 2015/849;

A. whereas the Union must ensure a high level of protection of the Union financial system from money laundering and terrorist financing risks;

B. whereas, according towhereas the 2020 methodology for identifying high-risk third countries under Directive (EU) 2015/849, set out in the Commission Staff Working Document of 7 May 2020 (the ‘2020 methodology’), the Commission can largely rely on the assessments of third countries carried out by international bodies, such as the Financial Action Task Force (FATF), since the assessment by the FATF follows due process2020, basedshould onbe objectiveobjective, criteriatransparent, and the specific thresholds for being listed permit identification ofautonomous, countriesreflecting presentingspecific veryUnion materialconcerns and profound strategic deficiencies; whereas, in principle, any third country representing a risk to the international financial system, as identified by the FATF, is presumed to represent a risk to the internal market;priorities;

C. whereas the Commission’sit assessmentis is,all however,the anmore autonomousimportant processfor whichthe hasCommission to be carried out inretain afull comprehensiveautonomy and unbiased manner, assessing all thirdresponsibility countriesin basedcarrying onout thean sameautonomous criteriaassessment that areaddresses setanti-money outlaundering inrisks Articlethrough 9(2)its ofown Directivetransparent (EU)and 2015/849;evidence-based methodology;

D. whereas Parliament expects the Commission to conduct its own assessment attending to the specific vulnerabilities of the internal market and not to rely solely on the assessments conducted by the FATF;

D. whereas the Commission continues to propose changes to the list en bloc, rather than assessing each country individually; whereas this approach prevents Parliament from assessing each country on its own merits and implies that some countries would be unfairly affected by an objection to the delegated act;

E. whereas, under the 2020 methodology, once a third country is delisted by the FATF, that third country is retained on the Union list of high-risk third countries until it has been established that that third country meets the Union criteria for removal; whereas that autonomous process implies that the delisting by the Union entails concrete assurances that that third country no longer poses a high risk to the integrity of the Union internal market specifically; whereas the thoroughness of the Commission’s assessment should be commensurate with the deficiencies identified, on the one hand, and the degree of exposure of the internal market to the third country in particular, on the other;

E. whereas the Commission’s continued practice of proposing changes to the list as a package prevents Parliament from voting on each jurisdiction individually; whereas that approach limits democratic scrutiny and undermines Parliament’s ability to target jurisdictions of particular concern; whereas Parliament would, for instance, strongly support the addition of Monaco to the list of high-risk third countries, if separate votes on individual jurisdictions were allowed;

F. whereas, on 10 June 2025, the Commission adopted a Commission delegated regulation amending Delegated Regulation (EU) 2016/1675 by adding Algeria, Angola, Côte d’Ivoire, Kenya, Laos, Lebanon, Monaco, Namibia, Nepal and Venezuela to the table in point I of the Annex and deleting Barbados, Gibraltar, Jamaica, Panama, the Philippines, Senegal, Uganda and the United Arab Emirates from the table;

F. whereas lower-income countries continue to be disproportionately affected by the Union listing of high-risk third countries, even in cases where they have demonstrated measurable progress in strengthening their anti-money laundering and counter-terrorist financing (AML/CFT) frameworks, as exemplified by Côte d’Ivoire; whereas, in those countries, existing shortcomings are often the result of administrative and institutional capacity constraints linked to limited resources, rather than a reflection of the jurisdiction’s actual role in facilitating money laundering or terrorist financing; whereas similar concerns have been raised in relation to the Union list of non-cooperative jurisdictions for tax purposes, where lower-income countries are also overrepresented despite limited global impact;

G. whereas it is the view of Parliament that the list of criteria set out in Article 9(2) of Directive (EU) 2015/849 is non-exhaustive (‘in particular’) and that predicate offences to money laundering, such as the evasion of sanctions, may fall under those criteria and should be duly taken into account in the autonomous assessment process of the Commission;

G. whereas the Commission proposes to remove the United Arab Emirates (UAE) from the list based largely on the Financial Action Task Force (FATF)’s decision to delist the country;

H. whereas the current Union listing process for high-risk third countries in the field of AML/CFT fails to address jurisdictions that pose serious systemic risks but are not included in the FATF list; whereas this includes countries that are no longer FATF members or have been suspended, that show persistent unwillingness to cooperate with international AML/CFT bodies, that are subject to wide-ranging Union or international financial sanctions, or that regularly violate international legal norms and international law; whereas the Commission has so far refrained from listing such jurisdictions, citing political and legal concerns, which undermines the credibility and effectiveness of the Union’s AML framework; whereas relying exclusively on FATF classifications is insufficient and overly restrictive, and additional criteria should be taken into account, such as enforcement of sanctions, transparency of beneficial ownership, cooperation with Union authorities, and compliance with international obligations;

H. whereas Parliament expects the Commission to conduct its own assessment taking into account the specific vulnerabilities of the internal market and not to rely solely on the assessment conducted by the FATF, taking into consideration that the degree of exposure of the internal market to the UAE may only increase should the bilateral free trade agreement come into effect;

I. whereas Russia is a clear example of a jurisdiction that warrants assessment under those broader criteria, given its suspension from FATF, its ongoing illegal war of aggression against Ukraine, and the widespread circumvention of Union sanctions; whereas similar situations are likely to occur in the future, and the Commission should be requested to submit a written proposal clarifying how it will address jurisdictions that are suspended from FATF, subject to sanctions, non-cooperative, or in breach of international law;

I. whereas the UAE is a major global financial and trading hub which, due to its geographical position and service-based economy attracting significant trade and foreign investment, poses significant risks; whereas the UAE is an increasingly important economic partner for the Union, being the Union’s main export destination and investment partner in the Middle East and North Africa region; whereas the UAE also serves as an important regional trade and logistics hub for Union operators;

J. whereas the fight against money laundering and terrorist financing is a continuous process, financial innovation is opening new routes and illicit flows can be quickly redirected; whereas more countries that are not on the list or are delisted must be closely observed, especially if there is potential for a steep increase in transactions; whereas while the Commission is responsible for performing this continuous work, Parliament believes that continuous dialogue with co-legislators is essential for keeping the framework functional and reacting quickly to possible threats;

J. whereas the Commission delegated regulation does not provide sufficient evidence or clear indications that the UAE has effectively implemented reforms resulting in tangible and verifiable improvements in the prevention and enforcement of AML/CFT measures;

K. whereas voting on all countries in a single act entails the risk that countries rightly proposed for delisting may not be removed from the list, and vice versa, if the co-legislators disagree with the Commission’s assessment, even when such disagreement concerns only one country;

K. whereas there is still no evidence that the UAE authorities have taken concrete and effective action to address potential money laundering activities in the real estate sector, particularly those involving politically exposed persons and individuals subject to credible allegations of financial crime, as documented by investigative journalists and supported by submissions from civil society organisations;

L. whereas, pursuant to Article 9(1) of Directive (EU) 2015/849, the Commission is empowered to adopt delegated acts to identify high-risk third countries whose deficiencies in AML/CFT systems pose a significant threat to the Union’s financial system; whereas Article 1(3), point (b), of Regulation (EU) 2024/1620 provides that the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) is to contribute to the identification and assessment of money laundering and terrorist financing risks and threats, including those originating from third countries that may affect the functioning of the internal market; whereas, therefore, reports, assessments or opinions issued by AMLA concerning third countries should be taken into account by the Commission pursuant to Article 9(4) of Directive (EU) 2015/849 when drawing up the list of high-risk third countries; whereas AMLA may exercise its role under Article 1(3), point (b), of Regulation (EU) 2024/1620 and thereby influence the drawing up of such a list by: (i) issuing opinions or technical advice, (ii) directly influencing the listing or delisting of countries by the FATF, and (iii) concluding administrative arrangements with the FATF that do not prejudice the respective competences of the Commission and the Member States;

L. whereas improving judicial and law enforcement cooperation with Member States and Union bodies and agencies is welcome; whereas, however, attention should also be paid to securing strong, verifiable commitments for improving real estate and beneficial ownership transparency, implementing an effective framework against financial crimes;

M. whereas, according to the EU TE-SAT 2025 and EU SOCTA 2025 reports by Europol, there is a growing and concerning nexus between organised crime, terrorist financing and money laundering; whereas criminal networks increasingly exploit emerging technologies, such as cryptocurrencies and digital financing systems, to launder illicit proceeds and fund violent extremist activities; whereas this convergence of threats undermines the integrity of the Union’s financial system and reinforces transnational criminal structures; whereas the instrumentalisation of young people and the use of advanced digital tools further exacerbate risks to the security and stability of the internal market;

M. whereas some progress was reported by Member States in enhancing their judicial and law enforcement cooperation with the UAE; whereas, however, more ambitious measures still need to be implemented; whereas the list of commitments provided by the UAE remains vague, lacking both concrete enforcement mechanisms and deadlines; whereas loopholes in the exchange of information between competent authorities on real estate and beneficial ownership information remain;

N. whereas despite legislative progress and stated commitments by the UAE to strengthen its AML/CTC framework, concerns persist regarding the role of the UAE as a jurisdiction used to conceal assets by individuals subject to international sanctions, ongoing criminal investigations, or credible allegations of corruption; whereas, given the rise in sanctions due to the geopolitical landscape, the FATF expressed its growing concerns regarding the financial connectivity of countries targeted by sanctions and jurisdictions subject to FATF countermeasures;

O. whereas serious and persistent deficiencies remain in the transparency of the real estate sector in the UAE, where transactions can take place without the mandatory involvement of any of the professionals subject to anti-money laundering obligations, and where real estate developers can directly sell properties without any obligation to screen clients and report suspicious activity; whereas longstanding and repeated evidence, including numerous journalistic investigations, has confirmed that the Dubai real estate market serves as a favoured destination for corrupt and criminal cash from around the world; whereas evidence from recent scandals has highlighted that such financial opacity has been exploited for money laundering, exposing important weaknesses in the UAE’s AML/CTF framework;

P. whereas the Commission’s proposal to remove the UAE from the list of high-risk third countries coincides with the relaunch of negotiations on a free trade agreement between the Union and the UAE; whereas, although there is no formal evidence that the delisting was directly requested by the UAE as part of the trade talks, the timing and context raise legitimate concerns that commercial or political considerations may have influenced a process that should remain strictly technical and risk-based;

Q. whereas the recent commitments made by the UAE are welcome; whereas, however, they remain insufficient to ascertain whether those reforms have been adequately implemented in practice and are producing tangible results;

R. whereas improvement in the AML/CFT legislative framework in the UAE is undeniable and very welcome, taking into consideration the elements outlined above; whereas, however, a delisting of the UAE from the Union’s list of high-risk third countries may not yet, however, properly ensure the protection of the integrity of the Union financial system, given the high exposure of the internal market to the UAE as a financial and trading hub; whereas a more thorough assessment of the risks and effective reforms carried out by the UAE is required before delisting the country;

1. Objects to the Commission delegated regulation;

2. Instructs its President to forward this resolution to the Commission and to notify it that the delegated regulation cannot enter into force;

3. Calls on the Commission to submit a new delegated act which takes account of the concerns set out above and of the following recommendations:above;

(a) reconsider the listing review procedure due to its shortcomings in addressing jurisdictions that pose serious systemic risks but are not included in the FATF list;

(b) avoid relying solely on FATF classifications, which are insufficient and overly restrictive, and take into account the role of AMLA;

4. Instructs its President to forward this resolution to the Council and to the governments and parliaments of the Member States.