No. 29 - The lists of countries with high money laundering risk: analysis and evaluation by Chiara Bentivogli and Francesca Di Natale

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July 2025

JEL Classification: F53, G28, K42

Keywords: money laundering, money laundering blacklists

The study presents some reflections on the criteria used by the official lists to assess the “foreign” risk of money laundering and on possible integrations to them, arising in particular from the specific characteristics of the country assessing the risk. The criteria for selecting countries at risk of money laundering included in official blacklists used in Italy and other indicators of money laundering risk developed by private institutions are examined. The study also presents an analysis of suspicious transaction reports received in 2022 by the Financial Information Unit for Italy that contain a link with foreign countries, whether or not they were on the official blacklist at the end of that year. The analysis also considers the results of unofficial indicators and other factors mentioned by the literature that are specific to the country where money laundering originates. The results confirm the high risk of financial transactions involving countries in the official blacklists and highlight the need to evaluate also “foreign” factors considered in “non official” indicators and proximity factors (geographical, cultural, commercial) that are specific to the country assessing the risk.