American Samoa — Country Risk Report

American Samoa (Offshore / IFC • US Pacific Territory). Risk report as of the 19 Jun 2026 FATF plenary.

Moderate country risk. American Samoa's country risk score is 1.7/10, placing it in the moderate-risk band. Some information is unavailable, so the available parts are rebalanced and the country will not be labelled Low risk while information is missing. The principal driver is weak rule of law and institutions. American Samoa is not currently FATF grey- or black-listed. American Samoa is not subject to comprehensive country-wide sanctions. Firms should apply additional scrutiny where exposure involves state-linked entities, restricted sectors, sensitive technology, dual-use goods or politically exposed counterparties.

Recommended treatment

Standard due diligence, with enhanced checks for defined risk triggers.

At a glance

• FATF status: Not currently listed (one indicator only; it does not set the overall country risk rating by itself)
• Comprehensive country sanctions: none identified. Targeted sanctions exposure: possible, screen applicable persons, entities and sectors
• Government effectiveness and rule of law: 2.8/10
• Corruption (CPI): no score
• Enforcement data: not yet assessed (no RegActions coverage)

Country Risk Score: 1.7/10 (Moderate)

Higher score means higher country risk (global average 4.6). Some information unavailable. Limited supporting information. Enforcement activity and CPI are shown for context but do not change the score.

One of the three parts is unavailable. The available parts are rebalanced, and the result will not be labelled Low risk while information is missing.

How this score was calculated

• Financial crime controls: information unavailable — 0% of this score
• Government effectiveness and rule of law: 2.8/10 — 60% of this score
• International sanctions: 0.0/10 — 40% of this score
• Financial crime controls information is unavailable.

International sanctions contributes 0.0 because the complete UN, UK, EU and US review found no direct country-level sanctions programme. People or organisations connected to the country may still appear on sanctions lists.

Principal risk drivers

• Government effectiveness and rule of law drive the score; no FATF listing or direct country-level sanctions were identified

Mitigating factors

• Not currently on the FATF grey or black list.
• No comprehensive country-wide sanctions programme.
• Comparatively stronger political stability (1.3/10).
• Risk is concentrated in specific counterparties, sectors and transactions rather than applying uniformly.

Business impact

• Customer onboarding (Medium): Additional ownership and control verification may be required.
• Payments and transactions (Medium): Review transaction purpose, counterparties and geographic routing.
• Trade and export activity (Medium): Screen goods, end users and potential dual-use exposure.
• Corporate clients (Medium): Assess state ownership, government links and political exposure.
• Ongoing monitoring (Medium): Apply alerts for ownership changes, sanctions and geopolitical developments.

Recommended controls

• Verify ultimate beneficial ownership using more than one reliable source.
• Identify state ownership, government influence and politically exposed persons.
• Screen entities, directors and beneficial owners against applicable sanctions lists.
• Apply enhanced review to technology, defence, telecommunications, financial services and dual-use activity.
• Document transaction purpose and source of funds where cross-border structures are complex.
• Escalate unresolved ownership opacity or adverse information to Compliance.

Enhanced due diligence triggers

• State ownership / control
• PEP involvement
• Sensitive / restricted sectors
• Opaque ownership
• Adverse media
• Dual-use goods & technology
• High-risk intermediary routing

FATF status: Not currently listed

American Samoa is not on the FATF grey or black list as of the 19 Jun 2026 plenary.

Source details

International sanctions by issuing body

• UN: No
• EU: No
• UK: No
• US: No

No means the complete UN, UK, EU and US review found no direct country-level programme. People or organisations may still appear on sanctions lists.

Government effectiveness and rule of law (World Bank 2024, percentile)

• Government Effectiveness: 66/100
• Regulatory Quality: 61/100
• Rule of Law: 76/100

Regulators and legal framework

FATF network

Outside the FATF regional network.

National regulators

Regulator profiles not yet available on RegActions.

FIU: Not an Egmont Group member

Framework signals

• FATF listing: Not currently listed
• International sanctions: no listed programme identified
• EU tax list: Listed (Annex I)
• Corruption (CPI): no score
• Rule of law (WGI): 3.2/10 risk

Sector exposure

• Banking & payments (Low): No FATF listing, rule-of-law governance within normal range
• Trade & export controls (Low): No sanctions programme or FATF black-list constraint identified
• Crypto & virtual assets (Low): No FATF listing, accountability governance within normal range
• Real estate & luxury assets (Low): Corruption indicators within normal range for high-value assets
• State-linked & procurement (Low): Political-stability and corruption governance within normal range

Derived from sanctions tier, FATF listing, World Bank WGI governance and CPI; no per-sector dataset is asserted.

American Samoa: analysis

American Samoa combines a complete World Bank governance evidence set with the practical characteristics of a small, non-sovereign Pacific territory. The WGI dimensions provide a usable institutional baseline, but they do not replace counterparty-level checks on ownership, tax residence or the use of offshore structures. The territory's appearance on the EU tax list is a tax cooperation signal rather than an AML or sanctions designation, and those categories should not be conflated. For firms, the useful approach is to preserve the distinction between US-linked legal infrastructure, local administrative capacity and the separate transparency concerns signalled by the tax listing.

Outlook

The profile should be monitored through official WGI revisions, changes to the EU tax list and any material development in US or territorial beneficial ownership requirements. Removal from or continued inclusion on the EU list would be a meaningful external signal, but it should be interpreted alongside the reason given by the Council and the effective date of any change. Because local enforcement volumes may remain low, absence of frequent actions should be treated as limited observation rather than proof of weak or strong supervision. New evidence should therefore update the narrative progressively without inventing a failure state between infrequent official releases.

Key watchpoints

• Council of the EU updates to the non-cooperative tax jurisdiction list and the stated basis for any change.
• World Bank WGI revisions across all six governance dimensions.
• US and territorial beneficial ownership, company registration and tax transparency requirements.
• Any official supervisory or enforcement publication affecting locally registered financial businesses.

Assessment currency

• FATF status: Not listed (as of 19 Jun 2026)
• Sanctions exposure: None identified (as of Jul 2026)
• Governance (WGI): Latest dataset incorporated (as of 2024)
• Corruption (CPI): Not available (as of 2025)
• RegActions assessment: Reviewed (as of 19 Jun 2026)

Public evidence layer

FATF action: none. No FATF call-for-action or increased-monitoring status was identified at the latest plenary. This does not establish low risk.

Contextual signals (not scored)

• FATF network membership: No FATF or regional-body membership identified (absent, as of 2026-07)
• EU non-cooperative tax jurisdictions: Listed in Annex I (present, as of 2026-02-17)
• Egmont Group FIU: No Egmont member FIU identified (absent, as of 2026-07-17)
• Beneficial-ownership register: No live register identified in the source (unavailable, as of 2026-07-17)
• Transparency International CPI: No CPI result available (unavailable, as of 2025)

Evidence freshness

• FATF monitored-jurisdiction status: current; data 2026-06-19
• FATF mutual evaluation and follow-up ratings: current; data 2026-07-31
• World Bank governance indicators: current; data 2024
• UN, UK, EU and US sanctions regimes: current; data 2026-08-16

Contextual signals are public evidence only and do not change the immutable v2 score.

Download evidence PDF · CSV · JSON

Regional peer scores

• British Virgin Islands: 6.0/10 (High)
• Sint Maarten: 5.6/10 (High)
• Curaçao: 4.5/10 (Moderate)
• Turks and Caicos Islands: 4.5/10 (Moderate)
• Barbados: 4.4/10 (Moderate)
• Antigua and Barbuda: 4.2/10 (Moderate)

Source: FATF black & grey lists · World Bank WGI (CC BY 4.0 — World Bank WGI) · TI CPI (CC BY-ND 4.0 — Transparency International, display only)