Ukraine — Country Risk Report

Ukraine (Europe • Eastern Europe). Risk report as of the 19 Jun 2026 FATF plenary.

Moderate country risk, with elevated corruption risk. Ukraine's country risk score is 4.2/10, placing it in the moderate-risk band. The principal driver is weak corruption, alongside rule of law and institutions risk. Ukraine is not currently FATF grey- or black-listed. Ukraine 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: 5.3/10
  • Corruption (CPI 2025): 36/100, rank #104 of 182
  • Enforcement data: not yet assessed (no RegActions coverage)

Country Risk Score: 4.2/10 (Moderate)

Higher score means higher country risk (global average 4.6). Full information available. Limited supporting information. 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: 5.3/10 — 50% of this score
  • Government effectiveness and rule of law: 5.3/10 — 30% of this score
  • International sanctions: 0.0/10 — 20% of this score
  • The FATF assessment is more than eight 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 5.3 × 50% + governance 5.3 × 30% + sanctions 0 × 20% = 4.2; final 4.2

Principal risk drivers

  • Corruption (WGI) — 6.6/10
  • Rule of law & institutions — 5.5/10

Mitigating factors

  • Not currently on the FATF grey or black list.
  • No comprehensive country-wide sanctions programme.
  • Comparatively stronger political stability (4.1/10).
  • 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

Ukraine 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: 40/100
  • Regulatory Quality: 50/100
  • Rule of Law: 45/100

Regulators and legal framework

FATF network

FATF network via MONEYVAL.

Last mutual evaluation: 2018 · report

National regulators

Regulator profiles not yet available on RegActions.

FIU: Egmont Group member (SFMS)

Framework signals

  • FATF listing: Not currently listed
  • International sanctions: no listed programme identified
  • BO register: Public (live since 2015)
  • Corruption (CPI 2025): 36/100, rank #104 of 182
  • Rule of law (WGI): 5.5/10 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 36/100)
  • State-linked & procurement (Elevated): State-capture exposure (corruption WGI 6.6/10)

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

Ukraine: analysis

Ukraine's profile is driven by a weak governance picture across all four domains. Corruption (elevated) is the dominant risk factor, supported by a weak CPI reading and a position below the median of the World Bank governance indicators. Rule of law and institutions (elevated) reflects longstanding concerns about the independence of the judiciary and state institutions. Political stability and voice and accountability are both elevated, reflecting the impact of the ongoing military conflict on institutional functioning. Ukraine is not on the FATF grey or black list and no sanctions regime targets Ukraine. No tracked enforcement data are available.

Outlook

Ukraine's risk profile remains elevated and is shaped primarily by the trajectory of the armed conflict and post-war reconstruction dynamics. Anti-corruption reform progress, including judicial independence and asset recovery, will be a key indicator. International support and EU accession negotiations may provide long-term governance improvement levers, but near-term risk is likely to remain high.

Key watchpoints

  • Corruption exposure in state procurement, reconstruction financing, and state-owned enterprise relationships.
  • PEP and beneficial ownership risk given the elevated concentration of political and economic power.
  • Any future FATF monitoring decisions relating to Ukraine's AML and counter-financing-of-terrorism framework.
  • Sanctions exposure through third-party relationships connected to sanctioned Russian entities or individuals operating via Ukrainian structures.

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): 36/100 (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: MONEYVAL (present, as of 2026-07)
  • EU non-cooperative tax jurisdictions: Not listed in Annex I (absent, as of 2026-02-17)
  • Egmont Group FIU: SFMS (present, as of 2026-07-17)
  • Beneficial-ownership register: Public (live since 2015) (present, as of 2026-07-17)
  • Transparency International CPI: 36/100, rank 104 (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 2020-09; base assessment 2018-01
  • World Bank governance indicators: current; data 2024
  • UN, UK, EU and US sanctions regimes: current; data 2026-08-16

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

Download evidence PDF · CSV · JSON

Regional peer scores

FAQ

Is Ukraine on the FATF grey list?

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

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

What is Ukraine's country risk rating?

RegActions rates Ukraine at 4.2/10 (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 Ukraine 36/100 (rank #104 of 182).

What due diligence applies to Ukraine?

Standard due diligence, with enhanced checks for defined risk triggers. This is decision-support based on Ukraine'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)