Marshall Islands — Country Risk Report

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

High country risk, with AML/CFT effectiveness gaps. Marshall Islands's country risk score is 5.3/10, placing it in the high-risk band. The principal score driver is AML/CFT effectiveness, contributing 3.4 of 5.3 points. Separately, the treatment overlays show that Marshall Islands is not currently FATF grey- or black-listed, and that Marshall Islands 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: 3.7/10
• Corruption (CPI): no score
• Enforcement data: not yet assessed (no RegActions coverage)

Country Risk Score: 5.3/10 (High)

Higher score means higher country risk (global average 5.5). Full information available. Composite score. Strong 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 5.0–5.4/10.

How this score was calculated

• AML/CFT effectiveness: 7.6/10 — 45% of this score
• Technical compliance: 2.7/10 — 20% of this score
• Governance and institutions: 3.7/10 — 35% of this score

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

Principal risk drivers

• AML/CFT effectiveness: 7.6/10 × 45% = 3.4 points
• Governance and institutions: 3.7/10 × 35% = 1.3 points
• Technical compliance: 2.7/10 × 20% = 0.5 points

Mitigating factors

• Not currently on the FATF grey or black list.
• No comprehensive country-wide sanctions programme.
• Comparatively stronger political stability (1.2/10).
• 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

Marshall 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: 46/100
• Regulatory Quality: 44/100
• Rule of Law: 71/100

Regulators and legal framework

FATF network

FATF network via APG.

• Asia/Pacific Group on Money Laundering

Last mutual evaluation: 2024 · report

National regulators

Regulator profiles not yet available on RegActions.

FIU: Egmont Group member (RMI-FIU)

Framework signals

• FATF listing: Not currently listed
• International sanctions: no direct country programme identified (legal treatment overlay remains applicable)
• Corruption (CPI): no score
• Rule of law (WGI): 4.6/10 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: 1.

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.

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

• Domestic Financial Intelligence Unit (DFIU) — Level 1: Identity confirmed · No public official website identified

  Mandates: Financial intelligence · Access status: No public official website identified · Research/publication snapshot checked: 2026-08-20

  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.

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

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 7.6/10
• Real estate & luxury assets (High): Beneficial-ownership subscore is 7.7/10
• State-linked & procurement (High): Effectiveness pillar risk is 7.6/10

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

Marshall Islands: analysis

The Republic of the Marshall Islands is a Pacific state in free association with the United States 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 mixed: political stability is very strong and accountability is strong, but rule of law (moderate) and corruption (moderate) are weaker. It sits in the upper-middle tier of the World Bank governance indicators, though no CPI data are published. The defining structural feature is its large non-resident corporate registry: the APG's third-round mutual evaluation, adopted in September 2024, found that non-resident domestic corporations are not required to disclose officers, directors, shareholders or beneficial owners to the Registrar, that corporate entities may act as directors and shareholders, and that the ML/TF risks of the offshore corporate and ship-registry sectors were insufficiently assessed and understood.

Outlook

The Marshall Islands' governance-based profile understates the practical exposure created by its opaque non-resident corporate registry, which the September 2024 APG evaluation identified as a significant vulnerability. The forward picture depends on the pace of APG follow-up remediation, particularly on beneficial ownership disclosure for non-resident corporations and on the risk understanding of the offshore and ship-registry sectors. Firms should apply enhanced due diligence to Marshall Islands non-resident entities and verify beneficial ownership independently of the Registrar.

Key watchpoints

• APG follow-up reporting on the September 2024 third-round mutual evaluation, especially beneficial ownership disclosure for non-resident corporations.
• Beneficial ownership verification for Marshall Islands non-resident domestic corporations; do not rely on the Registrar, which does not require officer or owner disclosure.
• Risk-understanding and supervision of the offshore corporate and ship-registry sectors.
• 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: RMI-FIU (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: 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 2026-08-24; follow-up 2024-11; base assessment 2024-11
• 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: 88/100 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

• North Korea: 8.6/10 (Very high)
• Myanmar: 7.8/10 (Very high)
• Afghanistan: 7.7/10 (Very high)
• Laos: 7.3/10 (Very high)
• Pakistan: 7.1/10 (Very high)
• Tonga: 7.1/10 (Very 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)