Kyrgyzstan — Country Risk Report

Kyrgyzstan (Asia Pacific • Central Asia). Risk report as of the 19 Jun 2026 FATF plenary.

High country risk, with AML/CFT effectiveness gaps. Kyrgyzstan's country risk score is 6.0/10, placing it in the high-risk band. The principal score driver is AML/CFT effectiveness, contributing 3.3 of 6.0 points. Separately, the treatment overlays show that Kyrgyzstan is not currently FATF grey- or black-listed, and that Kyrgyzstan 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

Enhanced due diligence where defined risk triggers are present, and documented justification for accepting the relationship.

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: 5.9/10
  • Corruption (CPI 2025): 26/100, rank #142 of 182
  • Enforcement data: not yet assessed (no RegActions coverage)

Country Risk Score: 6.0/10 (High)

Higher score means higher country risk (global average 5.5). Full information available. Composite score. 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.

All three underlying risk pillars are available. All three underlying risk pillars are available and weighted using the published formula. Weight sensitivity 5.8–6.1/10.

How this score was calculated

  • AML/CFT effectiveness: 7.3/10 — 45% of this score
  • Technical compliance: 3.0/10 — 20% of this score
  • Governance and institutions: 5.9/10 — 35% of this score

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

Show the exact calculation

effectiveness 7.3 × 45% + safeguards 3 × 20% + governance 5.9 × 35% = 6; sanctions and FATF listing are overlays except a labelled FATF listing substitute where no mutual evaluation exists

Principal risk drivers

  • AML/CFT effectiveness: 7.3/10 × 45% = 3.3 points
  • Governance and institutions: 5.9/10 × 35% = 2.1 points
  • Technical compliance: 3.0/10 × 20% = 0.6 points

Mitigating factors

  • Not currently on the FATF grey or black list.
  • No comprehensive country-wide sanctions programme.
  • Comparatively stronger political stability (4.3/10).
  • 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 (Enhanced): Review transaction purpose, counterparties and the full payment routing.
  • Trade and export activity (Enhanced): Screen goods, end users and potential dual-use exposure.
  • Corporate clients (Enhanced): Assess state ownership, government links and political exposure.
  • Ongoing monitoring (Enhanced): 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

Kyrgyzstan 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: 34/100
  • Regulatory Quality: 47/100
  • Rule of Law: 41/100

Regulators and legal framework

FATF network

FATF network via EAG.

Last mutual evaluation: 2018 · report

National regulators

Regulator profiles not yet available on RegActions.

FIU: Egmont Group member (FIS)

Framework signals

  • FATF listing: Not currently listed
  • International sanctions: no direct country programme identified (legal treatment overlay remains applicable)
  • Corruption (CPI 2025): 26/100, rank #142 of 182
  • Rule of law (WGI): 5.9/10 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: 3.

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.
How to read activity and enforcement visibility

Only qualified authority-owned routes can support Level 2 or Level 3. External official context and unqualified candidates do not promote the evidence level. Blocked and unavailable sources remain unknown.

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

  • National Bank of the Kyrgyz Republic — Level 1: Identity confirmed · Official site reachable

    Mandates: Central bank, Prudential supervision · Access status: Official site reachable · Research/publication snapshot checked: 2026-08-20

    Official authority site

    Provisional first-page scan signal

    Signal: unknown · Observed month count: 0 · Latest observed month: unknown.

    No qualified authority-owned dated route supports an activity signal. This is not evidence of inactivity; blocked, external-context, low-frequency and unvalidated sources remain unknown.

    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

    • Official authority-owned enforcement route: Сriminal sanction for counterfeiting

      Authority-owned and approved for the human-reviewed route contract.

      Route type: sanctions_or_penalty_list · Source scope: authority-owned · Qualification: approved-for-human-contract · Provisional scan signal: no-dated-first-page-signal · Observed months: 0 · Latest observed month: unknown

    • Unqualified publication candidate: Prices for refined gold ingots

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

      Route type: not classified · Source scope: not classified · Qualification: not classified · Provisional scan signal: not-observable · Observed months: 0 · Latest observed month: unknown

    • Unqualified publication candidate: next decision will be made onAugust 24, 2026

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

      Route type: not classified · Source scope: not classified · Qualification: not classified · Provisional scan signal: not-observable · Observed months: 0 · Latest observed month: unknown

  • State Service for Financial Market Regulation and Supervision under the Government of the Kyrgyz Republic — Level 1: Identity confirmed · Official site could not be reached

    Mandates: Securities · Access status: Official site could not be reached · 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.

    No publication candidate is qualified. Regulatory activity and enforcement visibility remain unknown.

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

  • The State Financial Intelligence Under the Government of the Kyrgyz Republic (FIS) — Level 1: Identity confirmed · Official site challenge-protected

    Mandates: Financial intelligence · 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

    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 (Elevated): Effectiveness pillar risk is 7.3/10
  • Real estate & luxury assets (High): BO subscore 6.1/10; CPI context 26/100
  • State-linked & procurement (High): Effectiveness pillar risk is 7.3/10

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

Kyrgyzstan: analysis

Kyrgyzstan's profile is driven by severe corruption and materially weak rule of law. Voice and accountability (elevated) is also elevated. Political stability is relatively less acute but remains a moderate concern. The CPI reading provides strong independent corroboration of entrenched corruption. No FATF listing or sanctions apply, so the profile reflects governance risk alone. Kyrgyzstan sits well below the median of assessed jurisdictions on the World Bank governance indicators.

Outlook

Kyrgyzstan's governance challenges are structural and long-standing. Corruption and institutional weakness are unlikely to improve materially in the short term. Firms should apply enhanced due diligence for Kyrgyz counterparties and monitor FATF plenary cycles given the jurisdiction's governance profile, which may attract heightened international scrutiny over time.

Key watchpoints

  • Monitor FATF plenary outcomes in October 2026 for any change in listing status, given the high governance risk profile.
  • Track corruption-related enforcement and any domestic reform measures affecting beneficial ownership transparency.
  • Assess exposure to state-linked entities and politically exposed persons given the corruption severe risk rating.
  • Review correspondent banking relationships in light of Kyrgyzstan's elevated risk and weak rule-of-law environment.

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): 26/100 (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: EAG (present, as of 2026-07)
  • EU non-cooperative tax jurisdictions: Not listed in Annex I (absent, as of 2026-02-17)
  • Egmont Group FIU: FIS (present, as of 2026-07-17)
  • Beneficial-ownership register: No live register identified in the source (unavailable, as of 2026-08-23)
  • Transparency International CPI: 26/100, rank 142 (present, as of 2025)

Evidence freshness

  • FATF monitored-jurisdiction status: current; data 2026-06-19
  • FATF mutual evaluation and follow-up ratings: current; data 2026-08-24; follow-up 2023-12; base assessment 2018-09
  • World Bank governance indicators: current; data 2024
  • UN, UK, EU and US sanctions regimes: current; data 2026-08-30

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: Not listed in EU Annex I. Annex I is a political/legal tax-cooperation list, not a general AML, corruption, or country-risk score. Source
  • Political stability and conflict: 57/100 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

FAQ

Is Kyrgyzstan on the FATF grey list?

No. Kyrgyzstan 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 Kyrgyzstan low risk. The next FATF plenary review is scheduled for Oct 2026.

Is Kyrgyzstan 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 Kyrgyzstan, but individual listed persons may still exist, so firms should continue to screen counterparties against the applicable lists.

What is Kyrgyzstan's country risk rating?

RegActions rates Kyrgyzstan at 6.0/10 (High risk), where a higher score means higher country risk. The v3 score combines AML/CFT effectiveness, technical compliance, and governance and institutions. FATF listing and sanctions are shown as overlays and do not add points. Transparency International's 2025 Corruption Perceptions Index scores Kyrgyzstan 26/100 (rank #142 of 182) as context only.

What due diligence applies to Kyrgyzstan?

Enhanced due diligence where defined risk triggers are present, and documented justification for accepting the relationship. This is decision-support based on Kyrgyzstan'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)