Cook Islands — Country Risk Report

Cook Islands (Asia Pacific • Oceania). Risk report as of the 19 Jun 2026 FATF plenary.

Moderate country risk, with elevated corruption risk. Cook Islands's country risk score is 3.5/10, placing it in the moderate-risk band. The principal driver is weak corruption. Cook Islands is not currently FATF grey- or black-listed. Cook Islands 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: 3.3/10
  • Corruption (CPI): no score
  • Enforcement data: not yet assessed (no RegActions coverage)

Country Risk Score: 3.5/10 (Moderate)

Higher score means higher country risk (global average 4.6). Full information available. Some evidence is older. Enforcement activity and CPI are shown for context but do not change the score.

All three parts of the score are available.

How this score was calculated

  • Financial crime controls: 5.0/10 — 50% of this score
  • Government effectiveness and rule of law: 3.3/10 — 30% of this score
  • International sanctions: 0.0/10 — 20% of this score
  • The FATF assessment is more than five years old.

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.

Show the exact calculation

aml 5 × 50% + governance 3.3 × 30% + sanctions 0 × 20% = 3.5; final 3.5

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 (1.4/10).
  • 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

Cook Islands 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: 62/100
  • Regulatory Quality: 56/100
  • Rule of Law: 73/100

Regulators and legal framework

FATF network

FATF network via APG.

Last mutual evaluation: 2018 · report

National regulators

Regulator profiles not yet available on RegActions.

FIU: Egmont Group member (CIFIU)

Framework signals

  • FATF listing: Not currently listed
  • International sanctions: no listed programme identified
  • Corruption (CPI): no score
  • Rule of law (WGI): 3.6/10 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.

Cook Islands: analysis

The Cook Islands is a self-governing state in free association with New Zealand and a member of the Asia/Pacific Group on Money Laundering (APG). Its risk picture is governance-derived, with no FATF or sanctions overlay. The governance base is strong: political stability is strong, accountability is moderate, rule of law is moderate, and corruption is the weakest domain. The Cook Islands sits in the upper third of the World Bank governance indicators, though no CPI data are published to corroborate the corruption reading independently. The jurisdiction is best known internationally for its asset-protection trust legislation, which has drawn scrutiny over transparency; the Cook Islands strengthened trustee-company supervision through the Trustee Companies Act and completed its most recent APG mutual evaluation in the 2017 to 2018 cycle.

Outlook

The Cook Islands' profile reflects a solid governance base tempered by its trust-centre exposure. The forward picture depends on the effectiveness of trustee-company and DNFBP supervision, beneficial ownership transparency for trust structures, and the corruption domain as the weakest governance reading. Firms should apply source-of-wealth and beneficial ownership scrutiny to Cook Islands trust relationships and monitor APG follow-up reporting for any change in status.

Key watchpoints

  • APG follow-up reporting and any next-round mutual evaluation developments for the Cook Islands.
  • Beneficial ownership and source-of-wealth transparency for Cook Islands asset-protection trusts; apply enhanced due diligence.
  • Effectiveness of trustee-company and DNFBP supervision under the Cook Islands framework.
  • Absence of CPI data limits independent corruption benchmarking; supplement with credible third-party indicators.

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: FATF regional network: APG (present, as of 2026-07)
  • EU non-cooperative tax jurisdictions: Not listed in Annex I (absent, as of 2026-02-17)
  • Egmont Group FIU: CIFIU (present, 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; follow-up 2018-09; base assessment 2018-09
  • 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

FAQ

Is Cook Islands on the FATF grey list?

No. Cook Islands is not on the FATF grey or black list as of the 19 Jun 2026 plenary. FATF listing is one AML indicator; absence from the list does not by itself make Cook Islands low risk. The next FATF plenary review is scheduled for Oct 2026.

Is Cook Islands subject to sanctions?

No country-level programme was identified. In the approved RegActions snapshot, no comprehensive or targeted country-wide sanctions programme was found for Cook Islands, but individual listed persons may still exist, so firms should continue to screen counterparties against the applicable lists.

What is Cook Islands's country risk rating?

RegActions rates Cook Islands at 3.5/10 (Moderate risk), where a higher score means higher country risk. The score combines financial crime controls, government effectiveness and rule of law, and international sanctions.

What due diligence applies to Cook Islands?

Standard due diligence, with enhanced checks for defined risk triggers. This is decision-support based on Cook Islands's FATF status, governance and sanctions signals, and is not a substitute for a firm's own risk assessment.

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)