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Kenya and Côte d’Ivoire have been added to the European Commission’s list of high-risk third countries for money laundering and terrorist financing under the EU’s AML framework.
The inclusions are made via a new Delegated Regulation, which cites recent publications from the global anti-money laundering watchdog, the Financial Action Task Force (FATF).
Both countries were found to have “strategic deficiencies” in their regimes for preventing money laundering and terrorist financing.
Commitments from Kenya and Côte d’Ivoire
The Commission says authorities in both countries have “committed” to remedying the deficiencies, including by working with FATF, the Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG) and the Groupe Intergouvernemental d’Action contre le Blanchiment d’Argent en Afrique de l’Ouest (GIABA).
In the case of Kenya, the country’s Parliament recently passed the Anti-Money Laundering and Combating of Terrorism Financing Laws (Amendment) Act, 2025, which is noted by EU monitors as a positive step.
What It Means for EU Businesses
Under EU rules, firms dealing with entities in high-risk jurisdictions must carry out enhanced due diligence (EDD). This includes:
- Collecting additional information on beneficial owners and source of funds
- Securing senior management approval before entering relationships
- Monitoring existing dealings more closely
- In some cases, avoiding setting up subsidiaries in those jurisdictions altogether
Sources also indicate that EU funds may be restricted from starting new operations with entities registered in Kenya or Côte d’Ivoire until reforms are fully implemented. Development finance institutions may maintain current projects but are expected to pause fresh investments.
Impact in the UK
The UK maintains a similar high-risk list aligned with FATF. Businesses operating in both the EU and UK will therefore need to apply the same enhanced controls when transacting with Kenyan or Côte d’Ivoirian partners.
The Current EU Grey List
Following this update, the Commission’s list of high-risk jurisdictions now includes:
Algeria, Angola, Bolivia, Bulgaria, Burkina Faso, Cameroon, Côte d’Ivoire, Democratic Republic of the Congo, Haiti, Kenya, Lao PDR, Lebanon, Monaco, Mozambique, Namibia, Nepal, Nigeria, South Africa, South Sudan, Syria, Venezuela, Vietnam, Virgin Islands (UK), and Yemen.
Next Steps
The Commission will review progress regularly, adjusting enhanced due diligence measures once deficiencies are addressed. For now, EU businesses must treat Kenya and Côte d’Ivoire as high-risk and adapt compliance processes accordingly.
👉 For more context on due diligence requirements, see our coverage of best AML software providers.
