The European Commission has taken another important step in strengthening the EU’s anti-money laundering and counter-terrorist financing framework. On 15 September 2025, it introduced a review clause through Commission Delegated Regulation (EU) 2025/1393, building on the high-risk third country update adopted on 10 June 2025.

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The European Commission has taken another important step in strengthening the EU’s anti-money laundering and counter-terrorist financing framework. On 15 September 2025, it introduced a review clause through Commission Delegated Regulation (EU) 2025/1393, building on the high-risk third country update adopted on 10 June 2025 (Commission press release).

This new clause requires the European Commission to conduct its own assessment of jurisdictions whose FATF membership has been suspended, even if they are not currently subject to FATF monitoring. The review must be completed by 31 December 2025 and could result in additional countries being designated as high-risk under EU law. The full text of the regulation can be accessed on EUR-Lex and more background on the EU’s AML/CFT regime is available via the European Commission’s AML portal.

For financial institutions, this change means that the EU may move faster than FATF in identifying risks, expanding the scope of jurisdictions where enhanced due diligence will apply. Compliance teams should anticipate potential updates by early 2026.

cleversoft Services

At cleversoft, we continuously align our solutions with regulatory developments. Once the review clause process is implemented and new jurisdictions are assessed, these updates will be seamlessly integrated into our Country Risk Assessment Matrix within cleverKYC. This ensures that your compliance processes remain accurate, consistent and fully up to date without additional manual effort.

If you would like to understand how this development may affect your business, or if you have any questions about our services, please contact us, who will be happy to assist you.