Guam — Country Risk Report

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

Moderate country risk. Guam's country risk score is 1.6/10, 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. Guam is not currently FATF grey- or black-listed. Guam 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: 2.6/10
• Corruption (CPI): no score
• Enforcement data: not yet assessed (no RegActions coverage)

Country Risk Score: 1.6/10 (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: 2.6/10 — 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 (1.7/10).
• 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

Guam 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: 76/100
• Regulatory Quality: 61/100
• Rule of Law: 75/100

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): 2.9/10 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.

Guam: analysis

Guam's institutional picture is anchored by a complete World Bank governance record and its constitutional relationship with the United States. That evidence supports governance analysis, but firms should still distinguish federal safeguards from local company, licensing and enforcement arrangements. The EU tax listing is the most prominent external transparency signal and concerns tax cooperation rather than a direct AML or sanctions classification. A proportionate assessment should therefore combine the official governance evidence, the precise basis of the tax listing and transaction-specific exposure instead of treating territorial status as a substitute for due diligence.

Outlook

Future movement is most likely to come from World Bank data revisions, Council of the EU tax list decisions, or changes in US and Guam transparency requirements. The tax list should be monitored for both additions and removals, with the accompanying Council explanation retained as evidence. Local regulatory publications may remain infrequent because of the size of the market, so a quiet period is best shown as a watch with a last-checked date. Any new local enforcement action, licensing change or beneficial ownership reform should be incorporated when officially published and should not be inferred from third-party summaries alone.

Key watchpoints

• Official changes to Guam's treatment on the EU list of non-cooperative tax jurisdictions.
• Complete six-dimension WGI revisions and any material movement in the institutional profile.
• US federal and Guam-specific beneficial ownership, tax transparency and licensing developments.
• Low-frequency official enforcement publications and evidence of changes in local supervisory capacity.

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 2026-08-13

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)