EU high-risk third countries and entry-into-force dates

Check the temporal version

The baseline is Regulation 2016/1675 as amended. At checking time, the Commission overview identified instruments 2026/46 and 2026/83, including additions effective on 29 January 2026. Regulation 2026/46 was adopted on 3 December 2025, published on 9 January 2026 and takes effect on the twentieth day after publication under Article 2. These dates must not be conflated.

Record whether the country appears in the legally relevant version. Historical transactions require historical versions; current transactions need current law. Assess existing clients when lists change during relationships. Announcements of planned changes may prompt preparation but cannot replace effective-date verification.

Link countries to the actual connection

Section 9a(2)(a) and (b) distinguishes relationships with persons whose country of origin is high-risk from transactions connected to such countries. Bank-account country or billing address alone is insufficient. Assess origin, activity, owners and funds flows. Apply relevant rules to country of origin and substantive connections.

For high-risk-country branches, Section 9a(4) requires at least paragraph 3(a)–(d) and (f) measures. This minimum differs from the PEP branch. Low automated scores cannot remove mandatory requirements. Choose additional measures according to identified risk and service type, with evidence of reasons and performance.

Enhanced due diligence is not a universal ban

Listing triggers relevant AML measures rather than automatic rejection of all residents. Sanctions or Section 15 due-diligence barriers may separately arise. Absence from the EU list does not exclude individual or other geographic risks. Record the source, effective date and follow-up actions rather than hardcoding a supposedly permanent table into static prose.

Evidence effective dates in the data output

A data output should distinguish adoption, publication, entry into force and check time. If showing only one date, clearly label its meaning. A new list cannot retrospectively demonstrate an older transaction’s legal status without explanation. Preserve the effective version and relevant act for historical assessments, rather than only today’s Commission-page snapshot. Timing is part of the reasoning.

When updating the application, verify additions and removals. A rule that only adds countries may preserve superseded mandatory statuses. Keep history separate from current decisions. Resolve uncertainty about entry into force through the published act and final provision. Until resolved, do not present the internal table as authoritative. Your geographic assessment may still justify measures, but their reason must be accurately labelled.