Somalia — Country Risk Report

Somalia (Africa • East Africa). Risk report as of the 19 Jun 2026 FATF plenary.

Very high country risk, with elevated corruption risk. Somalia's country risk score is 7.3/10, placing it in the very 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. Somalia is not currently FATF grey- or black-listed. Somalia 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: 7.9/10
  • Corruption (CPI 2025): 9/100, rank #181 of 182
  • Enforcement data: not yet assessed (no RegActions coverage)

Country Risk Score: 7.3/10 (Very 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: 7.9/10 — 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.
Show the exact calculation

governance 7.9 × 60% + sanctions 6.4 × 40% = 7.3; sanctions-sectoral floor 6 non-binding; final 7.3

Principal risk drivers

  • Sectoral sanctions exposure
  • Corruption (WGI) — 8.8/10
  • Rule of law & institutions — 8.0/10
  • Political stability — 7.3/10
  • Voice & accountability — 7.1/10

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 (Enhanced): Additional ownership and control verification may be required.
  • Payments and transactions (Enhanced): Review transaction purpose, counterparties and geographic 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): 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

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

Sanctions: Sectoral

  • EU — sectoral: Restrictive measures in view of the situation in Somalia (source)
  • OFAC — targeted: Somalia Sanctions (source)
  • UK — sectoral: Somalia sanctions (source)
  • UN — sectoral: Al-Shabaab / Somalia 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: 13/100
  • Regulatory Quality: 28/100
  • Rule of Law: 19/100

Regulators and legal framework

FATF network

FATF network via MENAFATF.

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): 9/100, rank #181 of 182
  • Rule of law (WGI): 8.0/10 risk

Sector exposure

  • Banking & payments (Elevated): Weak rule-of-law governance (WGI 8.0/10 risk)
  • Trade & export controls (High): Sectoral sanctions: Restrictive measures in view of the situation in Somalia
  • Crypto & virtual assets (Elevated): Weak accountability governance (WGI 7.1/10 risk)
  • Real estate & luxury assets (High): Severe corruption exposure (CPI 9/100) drives laundering risk
  • State-linked & procurement (High): High state-capture risk (corruption WGI 8.8/10)

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

Somalia: analysis

Somalia's profile reflects governance failure across all four domains. Corruption (weighted 35%) and rule of law (weighted 40%) are the dominant drivers and together represent the near-total absence of functional institutional controls. Political stability (severe) and voice and accountability (elevated) are also severely elevated. Somalia is not on the FATF grey or black list and carries no sanctions; however, its governance profile places it at the extreme end of inherent financial-crime risk. Somalia sits in the lowest quartile of the World Bank governance indicators. The CPI reading confirms the depth of the structural problem.

Outlook

Somalia's very high risk profile is driven by deep structural factors including protracted conflict, institutional fragility, and near-absent regulatory capacity. Meaningful risk reduction would require sustained and verifiable improvements in state capacity, rule of law, and financial sector governance over an extended period. Firms should treat Somalia as requiring the most stringent enhanced due diligence measures and should monitor any future FATF listing decisions carefully.

Key watchpoints

  • Watch for any FATF grey or black list designation, which the governance profile would readily support.
  • Monitor developments in state capacity, particularly in financial sector regulation and supervision.
  • Apply the most stringent enhanced due diligence to any transactions or relationships with a Somali nexus.
  • Track political stability and conflict dynamics, which directly affect AML/CFT enforcement viability.

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): 9/100 (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: 9/100, rank 181 (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

FAQ

Is Somalia on the FATF grey list?

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

Is Somalia subject to sanctions?

Partly. Somalia has sectoral sanctions exposure rather than a comprehensive country-wide programme. Firms should screen applicable persons, entities and sectors against the OFAC, UK, EU and UN lists.

What is Somalia's country risk rating?

RegActions rates Somalia at 7.3/10 (Very high risk), where a higher score means higher country risk. The score combines financial crime controls, government effectiveness and rule of law, and international sanctions. Some information is unavailable, so the available parts are rebalanced and the country will not be labelled Low risk while information is missing. Transparency International's 2025 Corruption Perceptions Index scores Somalia 9/100 (rank #181 of 182).

What due diligence applies to Somalia?

Enhanced due diligence. This is decision-support based on Somalia'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)