Libya — Country Risk Report

Libya (Africa • North Africa). Risk report as of the 19 Jun 2026 FATF plenary.

High country risk, with elevated corruption risk. Libya's country risk score is 6.9/10, placing it in the high-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 corruption, alongside rule of law and institutions risk. Libya is not currently FATF grey- or black-listed. Libya 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

Enhanced due diligence.

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: programmes in place, screen applicable lists
• Government effectiveness and rule of law: 7.3/10
• Corruption (CPI 2025): 13/100, rank #177 of 182
• Enforcement data: not yet assessed (no RegActions coverage)

Country Risk Score: 6.9/10 (High)

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: 7.3/10 — 60% of this score
• International sanctions: 6.4/10 — 40% of this score
• Financial crime controls information is unavailable.
• sector-wide international sanctions sets a minimum of 6.0, but the calculated score was already higher.

Principal risk drivers

• Sectoral sanctions exposure
• Corruption (WGI) — 8.3/10
• Rule of law & institutions — 7.4/10
• Political stability — 6.7/10
• Voice & accountability — 6.7/10

Mitigating factors

• Not currently on the FATF grey or black list.
• No comprehensive country-wide sanctions programme.
• Risk is concentrated in specific counterparties, sectors and transactions rather than applying uniformly.

Business impact

• Customer onboarding (High): Additional ownership and control verification may be required.
• Payments and transactions (High): Review transaction purpose, counterparties and geographic routing.
• Trade and export activity (High): Screen goods, end users and potential dual-use exposure.
• Corporate clients (High): Assess state ownership, government links and political exposure.
• Ongoing monitoring (High): 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

Libya is not on the FATF grey or black list as of the 19 Jun 2026 plenary.

Sanctions: Sectoral

• EU — sectoral: Prohibiting the satisfying of certain claims in relation to transactions that have been prohibited by the UN Security Council Resolution 883 (1993) and related resolutions (source)
• EU — sectoral: Restrictive measures in view of the situation in Libya (source)
• OFAC — targeted: Libya Sanctions (source)
• UK — sectoral: Libya sanctions (source)
• UN — sectoral: 1970 Libya sanctions (source)

Source details

International sanctions by issuing body

• UN: Yes (Sectoral)
• EU: Yes (Sectoral)
• UK: Yes (Sectoral)
• US: Yes (Targeted)

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: 24/100
• Regulatory Quality: 27/100
• Rule of Law: 28/100

Regulators and legal framework

FATF network

FATF network via MENAFATF.

• Middle East and North Africa Financial Action Task Force

National regulators

Regulator profiles not yet available on RegActions.

FIU: Not an Egmont Group member

Framework signals

• FATF listing: Not currently listed
• International sanctions: sectoral exposure
• Corruption (CPI 2025): 13/100, rank #177 of 182
• Rule of law (WGI): 7.4/10 risk

Sector exposure

• Banking & payments (Elevated): Weak rule-of-law governance (WGI 7.4/10 risk)
• Trade & export controls (High): Sectoral sanctions: Prohibiting the satisfying of certain claims in relation to transactions that have been prohibited by the UN Security Council Resolution 883 (1993) and related resolutions
• Crypto & virtual assets (Elevated): Weak accountability governance (WGI 6.7/10 risk)
• Real estate & luxury assets (High): Severe corruption exposure (CPI 13/100) drives laundering risk
• State-linked & procurement (High): High state-capture risk (corruption WGI 8.3/10)

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

Libya: analysis

Libya's profile is entirely governance-driven, with no FATF listing or sanctions overlay. Despite the absence of formal listings, the governance picture is severe across all domains. Corruption is the dominant driver; rule of law and institutions and political stability reinforce a picture of institutional fragility. Voice and accountability offers no significant relief. Libya is not on the FATF grey or black list and faces no sanctions exposure at this time. The CPI reading,. No enforcement actions are tracked.

Outlook

Libya's risk profile reflects prolonged state fragility and the near-absence of functioning AML infrastructure. Without significant stabilisation of governance and security conditions, the risk score is unlikely to improve materially. Firms should treat the absence of a FATF listing as providing limited assurance given the severity of underlying governance deficiencies. The October 2026 plenary may bring Libya's AML framework under closer scrutiny.

Key watchpoints

• Monitor FATF mutual evaluation progress and any grey-list consideration given the severe governance environment.
• Apply the highest levels of due diligence and senior management approval for any Libya-connected business.
• Track political and security developments closely, as state fragility directly affects AML control effectiveness.
• Verify beneficial ownership with heightened scepticism given the corruption score and CPI ranking.

Assessment currency

• FATF status: Not listed (as of 19 Jun 2026)
• Sanctions exposure: Targeted programmes in place (as of Jul 2026)
• Governance (WGI): Latest dataset incorporated (as of 2024)
• Corruption (CPI): 13/100 (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: MENAFATF (present, as of 2026-07)
• EU non-cooperative tax jurisdictions: Not listed in Annex I (absent, 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: 13/100, rank 177 (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
• 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

• Central African Republic: 7.8/10 (Very high)
• Democratic Republic of the Congo: 7.6/10 (Very high)
• Somalia: 7.3/10 (Very high)
• South Sudan: 7.3/10 (Very high)
• Sudan: 7.1/10 (Very high)
• Eritrea: 6.9/10 (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)