Kyrgyzstan — Country Risk Report

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

Moderate country risk, with elevated corruption risk. Kyrgyzstan's country risk score is 4.8/10, placing it in the moderate-risk band. The principal driver is weak corruption, alongside rule of law and institutions risk. Kyrgyzstan is not currently FATF grey- or black-listed. Kyrgyzstan 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: 5.9/10
  • Corruption (CPI 2025): 26/100, rank #142 of 182
  • Enforcement data: not yet assessed (no RegActions coverage)

Country Risk Score: 4.8/10 (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: 6.0/10 — 50% of this score
  • Government effectiveness and rule of law: 5.9/10 — 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 6 × 50% + governance 5.9 × 30% + sanctions 0 × 20% = 4.8; final 4.8

Principal risk drivers

  • Corruption (WGI) — 7.5/10
  • Rule of law & institutions — 5.9/10
  • Voice & accountability — 5.7/10

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 (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

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 listed programme identified
  • Corruption (CPI 2025): 26/100, rank #142 of 182
  • Rule of law (WGI): 5.9/10 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 (Elevated): Elevated corruption exposure (CPI 26/100)
  • State-linked & procurement (High): High state-capture risk (corruption WGI 7.5/10)

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 2026-07-17)
  • 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 2026-07-31; follow-up 2023-12; base assessment 2018-09
  • World Bank governance indicators: current; data 2024
  • UN, UK, EU and US sanctions regimes: current; data 2026-08-13

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

Download evidence PDF · CSV · JSON

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 4.8/10 (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. Transparency International's 2025 Corruption Perceptions Index scores Kyrgyzstan 26/100 (rank #142 of 182).

What due diligence applies to Kyrgyzstan?

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