Vatican City — Country Risk Report

Vatican City (Europe • Southern Europe). Risk report as of the 19 Jun 2026 FATF plenary.

Moderate country risk. Vatican City's country risk score is 3.3/10, placing it in the moderate-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 its governance profile. Vatican City is not currently FATF grey- or black-listed. Vatican City 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: information unavailable
• Corruption (CPI): no score
• Enforcement data: not yet assessed (no RegActions coverage)

Country Risk Score: 3.3/10 (Moderate)

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: 4.6/10 — 71% of this score
• Government effectiveness and rule of law: information unavailable — 0% of this score
• International sanctions: 0.0/10 — 29% of this score
• Government effectiveness and rule of law information is unavailable.
• 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.

Principal risk drivers

• Government effectiveness and rule of law drive the score; no FATF listing or direct country-level sanctions were identified

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 (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

Vatican City 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: no data
• Regulatory Quality: no data
• Rule of Law: no data

Regulators and legal framework

FATF network

FATF network via MONEYVAL.

• Committee of Experts on the Evaluation of Anti-Money Laundering Measures (MONEYVAL)

Last mutual evaluation: 2021 · report

National regulators

Regulator profiles not yet available on RegActions.

FIU: Egmont Group member (ASIF)

Framework signals

• FATF listing: Not currently listed
• International sanctions: no listed programme identified
• Corruption (CPI): no score
• Rule of law (WGI): no data

Sector exposure

• Banking & payments (Review): Rule-of-law evidence unavailable; no low-exposure conclusion
• Trade & export controls (Low): No sanctions programme or FATF black-list constraint identified
• Crypto & virtual assets (Review): Accountability evidence unavailable; no low-exposure conclusion
• Real estate & luxury assets (Review): Corruption-control evidence unavailable; no low-exposure conclusion
• State-linked & procurement (Review): Governance evidence incomplete; no low-exposure conclusion

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

Vatican City: analysis

Vatican City State, and the Holy See under whose sovereignty it falls, form a unique jurisdiction whose financial system centres on the Institute for the Works of Religion and is supervised by the ASIF (Supervisory and Financial Information Authority). World Bank WGI governance domain data are not published for Vatican City, so its headline scoring rests on a limited evidence base; the data gap is not itself a positive or negative assessment. No CPI data or governance percentile are available. The jurisdiction is assessed by MONEYVAL: its 2021 mutual evaluation, following an on-site visit in late 2020, rated the AML/CFT framework at five substantial and six moderate effectiveness outcomes with no low rating, and a follow-up report in 2024 noted further progress on banking and legal-persons measures. No FATF or sanctions escalators apply.

Outlook

Vatican City's forward risk picture rests on the MONEYVAL follow-up process and on the continued implementation of the reforms recognised in the 2021 evaluation, given the limited governance evidence base. The effectiveness of ASIF supervision, the outcome of high-profile domestic financial prosecutions, and transparency around the Institute for the Works of Religion are the primary monitoring considerations. Any future WGI data availability would allow a modelled risk picture to be constructed.

Key watchpoints

• MONEYVAL follow-up reporting on the Holy See and Vatican City State, building on the 2021 mutual evaluation.
• Effectiveness of ASIF supervision and the outcome of domestic financial-crime prosecutions.
• Transparency and governance around the Institute for the Works of Religion and Vatican asset management.
• Absence of WGI, CPI and percentile data makes independent risk calibration difficult; supplement with the MONEYVAL evaluation and third-party assessments.

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: 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: ASIF (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: 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 2026-07-31; follow-up 2024-05; base assessment 2021-08
• 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

• Belarus: 6.0/10 (High)
• Bosnia and Herzegovina: 6.0/10 (High)
• Bulgaria: 6.0/10 (High)
• Monaco: 6.0/10 (High)
• Montenegro: 6.0/10 (High)
• Russia: 6.0/10 (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)