Vatican City — Country Risk Report

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

Moderate country risk, with AML/CFT effectiveness gaps. Vatican City's country risk score is 4.6/10, 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 score driver is AML/CFT effectiveness, contributing 3.6 of 4.6 points. Separately, the treatment overlays show that Vatican City is not currently FATF grey- or black-listed, and that Vatican City 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

Standard due diligence for most relationships, with enhanced checks where defined risk triggers are present.

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: information unavailable
• Corruption (CPI): no score
• Enforcement data: not yet assessed (no RegActions coverage)

Country Risk Score: 4.6/10 (Moderate)

Higher score means higher country risk (global average 5.5). Some information unavailable. Provisional composite score. Limited 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.

Some underlying pillars are unavailable. Available weights are rebalanced; missing evidence is not treated as low risk. Some underlying evidence is unavailable; the available pillars are reweighted transparently and the result should not be treated as equally certain as a composite score. Weight sensitivity 4.5–4.7/10.

How this score was calculated

• AML/CFT effectiveness: 5.2/10 — 69% of this score
• Technical compliance: 3.2/10 — 31% of this score
• Governance and institutions: information unavailable — 0% of this score
• World Bank governance data is incomplete

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

Principal risk drivers

• AML/CFT effectiveness: 5.2/10 × 69% = 3.6 points
• Technical compliance: 3.2/10 × 31% = 1.0 points

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): Verify ultimate beneficial ownership and control from more than one source.
• Payments and transactions (Elevated): Review transaction purpose, counterparties and the full payment routing.
• Trade and export activity (Elevated): Screen goods, end users and potential dual-use exposure.
• Corporate clients (Review): Assess state ownership, government links and political exposure.
• Ongoing monitoring (Elevated): 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

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 direct country programme identified (legal treatment overlay remains applicable)
• Corruption (CPI): no score
• Rule of law (WGI): no data

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

• Financial Information Authority (AIF) — Level 1: Identity confirmed · Official site could not be reached

  Mandates: Financial intelligence · Access status: Official site could not be reached · Research/publication snapshot checked: 2026-08-20

  Official authority site

  Provisional first-page scan signal

  Signal: unknown · Observed month count: unknown · Latest observed month: unknown.

  Source access was limited during this research check, so activity remains unknown. This is not evidence of inactivity.

  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.

  Activity and enforcement visibility remain unknown; this access limitation does not establish that the authority has no enforcement activity.

Download regulatory ecosystem PDF · CSV · JSON

Sector exposure

• Banking & payments (Review): Governance pillar unavailable; no low-exposure conclusion
• Trade & export controls (Low): No direct sanctions or FATF call-for-action overlay identified
• Crypto & virtual assets (Low): No FATF overlay and effectiveness pillar within normal range
• Real estate & luxury assets (Review): Governance evidence unavailable; no low-exposure conclusion
• State-linked & procurement (Low): Current risk pillars show no elevated procurement signal

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 2026-08-23)
• 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 2024-05; base assessment 2021-08
• 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: Not available. WGI is an institutional perception indicator, not a conflict event feed or a prediction of future violence. Candidate sources are research leads only; they have not been ingested as evidence.
• 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

• Bosnia and Herzegovina: 6.0/10 (High)
• Bulgaria: 5.7/10 (High)
• Azerbaijan: 5.3/10 (High)
• Hungary: 5.3/10 (High)
• Ukraine: 5.3/10 (High)
• Albania: 5.2/10 (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)