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 2.8/10, 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 score driver is governance and institutions, contributing 2.8 of 2.8 points. Separately, the treatment overlays show that American Samoa is not currently FATF grey- or black-listed, and that American Samoa is not subject to comprehensive country-wide sanctions and has no direct country-level programme identified. 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 for most relationships, with enhanced checks where defined risk triggers are present.

At a glance

• FATF status: Not currently listed (one indicator only; it does not set the overall country risk rating by itself)
• No direct country-level sanctions programme identified; sanctions remain a legal treatment overlay and applicable lists must still be screened.
• Governance and institutions: 2.8/10
• Corruption (CPI): no score
• Enforcement data: not yet assessed (no RegActions coverage)

Country Risk Score: 2.8/10 (Moderate)

Higher score means higher country risk (global average 5.5). Some information unavailable. Indicative governance proxy. Limited supporting evidence. Enforcement activity and CPI are context only; FATF listing and sanctions are regulatory overlays except the labelled FATF listing status used where no mutual evaluation exists.

Some underlying pillars are unavailable. Available weights are rebalanced; missing evidence is not treated as low risk. Only World Bank governance evidence is available. This remains visible for discovery but is excluded from exact global ranking.

How this score was calculated

• AML/CFT effectiveness: information unavailable — 0% of this score
• Technical compliance: information unavailable — 0% of this score
• Governance and institutions: 2.8/10 — 100% of this score
• FATF effectiveness ratings are incomplete
• FATF technical safeguard ratings are incomplete
• Only one line of evidence is available, so the score is indicative rather than a composite

Sanctions treatment: No direct programme identified. FATF treatment: none.

Principal risk drivers

• Governance and institutions: 2.8/10 × 100% = 2.8 points

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 (Enhanced): Verify ultimate beneficial ownership and control from more than one source.
• Payments and transactions (Elevated): Review transaction purpose, counterparties and the full payment routing.
• Trade and export activity (Elevated): Screen goods, end users and potential dual-use exposure.
• Corporate clients (Standard): Assess state ownership, government links and political exposure.
• Ongoing monitoring (Elevated): Alert on ownership changes, new designations and status changes.

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 direct country programme identified (legal treatment overlay remains applicable)
• EU tax list: Listed (Annex I)
• Corruption (CPI): no score
• Rule of law (WGI): 3.2/10 risk

Regulatory ecosystem and enforcement visibility

This evidence map is separate from Country Risk v3. It describes official mandates, publication access and RegActions coverage; it does not judge regulatory strength or add points to country risk.

Transparency Index: not scored · Evidence disposition: local-authority-evidence · Mapped official authorities: 1.

Evidence level: Level 1: Identity confirmed. The ladder uses the authority evidenceLevel schema directly and does not infer a level from a URL, site access or RegActions feed count.

1. 1. Identity confirmed — The authority and its mandate are evidenced by official directory provenance.
2. 2. Regulatory activity visible — A qualified authority-owned route has provisional dated activity in the first-page scan.
3. 3. Enforcement visible — A qualified authority-owned enforcement route has provisional dated activity in the first-page scan.
4. 4. Score eligible — Shown only when the authority evidence schema explicitly records score-eligible; no authority currently does.

Enforcement visibility: No authority is classified enforcement-visible or score-eligible in the authority evidence schema. Enforcement visibility remains unknown or limited to identity/activity evidence; this is not evidence of no enforcement.

Authorities and mandate evidence

• Office of the Insurance Commissioner — Level 1: Identity confirmed · Official site challenge-protected

  Mandates: Insurance · Access status: Official site challenge-protected · Research/publication snapshot checked: 2026-08-20

  Official authority site

  Provisional first-page scan signal

  Signal: unknown · Observed month count: unknown · Latest observed month: unknown.

  Source access was limited during this research check, so activity remains unknown. This is not evidence of inactivity.

  Scan contract and precision

  automated-first-page-date-scan · 2024-01 to 2026-08 · as of 2026-08-20 · month precision · first-page-only-unvalidated. This is not a validated engagement frequency.

  Publication candidates and qualification

  • Unqualified publication candidate: NOTICES

    Research candidate only; it is not promoted to an official enforcement or regulatory-update route.

    Route type: not-observable · Source scope: not-observable · Qualification: browser-review-required · Provisional scan signal: unknown · Observed months: unknown · Latest observed month: unknown

  Activity and enforcement visibility remain unknown; this access limitation does not establish that the authority has no enforcement activity.

Download regulatory ecosystem PDF · CSV · JSON

Sector exposure

• Banking & payments (Low): No FATF overlay and governance pillar within normal range
• Trade & export controls (Low): No direct sanctions or FATF call-for-action overlay identified
• Crypto & virtual assets (Review): Effectiveness pillar unavailable; no low-exposure conclusion
• Real estate & luxury assets (High): Beneficial-ownership subscore is 9.0/10
• State-linked & procurement (Low): Current risk pillars show no elevated procurement signal

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 2026-08-23)
• 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: stale; data 2026-08-16

Contextual signals are public evidence only and do not change the current country-risk score.

Download evidence PDF · CSV · JSON

Contextual risk evidence (not scored)

These eight evidence families provide context only. They do not change the v3.1 headline score. Unavailable means no reviewed, country-comparable evidence is currently ingested; it does not mean the risk is absent.

• Organised crime: Not available. No reviewed country-level organised-crime dataset is currently checked in; no risk value is inferred. Candidate sources are research leads only; they have not been ingested as evidence.
• Fraud and cybercrime: Not available. No reviewed country-level fraud or cybercrime dataset is currently checked in; no risk value is inferred. Candidate sources are research leads only; they have not been ingested as evidence.
• Terrorism and proliferation financing: Not available. No reviewed country-comparable terrorism/proliferation threat dataset is currently checked in; FATF listing status remains a separate overlay. Candidate sources are research leads only; they have not been ingested as evidence.
• Trafficking: Not available. No reviewed country-level trafficking dataset is currently checked in; no risk value is inferred. Candidate sources are research leads only; they have not been ingested as evidence.
• Financial secrecy and offshore exposure: Not available. No reviewed, licence-clean financial-secrecy index is currently checked in; jurisdiction type alone is not used as a proxy. Candidate sources are research leads only; they have not been ingested as evidence.
• Tax cooperation: EU Annex I listed. Annex I is a political/legal tax-cooperation list, not a general AML, corruption, or country-risk score. Source
• Political stability and conflict: 87/100 WGI percentile. WGI is an institutional perception indicator, not a conflict event feed or a prediction of future violence. Source
• Beneficial ownership: Not available. The Open Ownership map is a live-register snapshot and absence means no register was identified in that snapshot, not that no register exists. Candidate sources are research leads only; they have not been ingested as evidence.

Regional peer scores

• Sint Maarten: 7.8/10 (Very high)
• British Virgin Islands: 6.8/10 (High)
• Curaçao: 6.3/10 (High)
• Turks and Caicos Islands: 6.2/10 (High)
• Barbados: 5.5/10 (High)
• Gibraltar: 5.5/10 (High)

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)