Financial Integrity Monitor

Antigua and Barbuda AG

Sources
8
Jurisdiction profile
CompliantTier BRisk: StableMixed

AML/CFT governed by the Money Laundering (Prevention) Act 1996 (as amended) and Prevention of Terrorism Act 2005, supervised by ONDCP (Supervisory Authority and FIU) with FSRC co-supervising international banks, insurance, gaming and VASPs under the Digital Business Assets Act.

MoreCFATF member; 2018 MER plus 2021 Follow-Up Report show moderate effectiveness with persistent gaps on PF sanctions, NPOs and DNFBP supervision.

Key deficiencies
  • Citizenship-by-Investment Programme rated medium-high ML/TF vulnerability with no mandatory ML/TF risk-assessment requirement and limited compliance audit function
  • Targeted financial sanctions for proliferation (R.7) remain only partially compliant; no clear freezing guidance for FIs/DNFBPs
  • Non-profit organisation sector TF risk not adequately identified or mitigated (R.8 rated Non-Compliant)
  • Open international ship registry repeatedly exploited by Iran- and Russia-sanctions-evasion shadow-fleet tankers
  • First National Risk Assessment (2017) never publicly released; update launched Jan 2025 still unpublished
Recent developments (18m)
  • NOCFA/ONDCP launched an updated National Risk Assessment exercise (27 Jan 2025)
  • US White House travel-ban proclamation (16 Dec 2025) targeting Antigua and Barbuda's CBI programme, effective January 2026
  • Formation of the Eastern Caribbean Citizenship by Investment Regulatory Authority (Sept 2025) with US Treasury/DHS, EU Commission and UK input
  • Multiple OFAC SDN designations of Antigua & Barbuda-flagged tankers and Antigua-incorporated shipping entities for Iran and Russia oil sanctions evasion (Apr 2025, Aug 2025, Jul 2026)
  • Active preparation for CFATF Fifth Round Mutual Evaluation, reaffirmed at the 61st CFATF Plenary, Nov 2025
Regulatory horizon
No dated horizon items this cycle. 4 items tracked without a confirmed date.
4 pending date · baseline financial-integrity-2026-10-03
Registers

Enforcement actions

  • OFAC added the Antigua & Barbuda-flagged tanker GLOBAL DOMINANCE to the SDN list under the Iran sanctions program for its role in transporting Iranian-origin petroleum. 10 Apr 2025
  • OFAC designated two Antigua and Barbuda-flagged tankers under the Iran sanctions program, both linked to Ozarka Shipping - FZCO, for facilitating Iranian petroleum trade. 21 Aug 2025
  • OFAC designated five Antigua and Barbuda-flagged general cargo, bulk carrier and container vessels under the Iran sanctions program as part of a wider Iran-related designation and update action. 14 Jul 2026
  • A presidential proclamation imposed a US travel ban on Antigua and Barbuda (and Dominica), citing the historic lack of residency requirements in the CBI programme and the resulting risk of identity concealment for sanctions and law-enforcement evasion. 16 Dec 2025
  • Antigua and Barbuda's NOCFA delegation (including FSRC, ODPP, Royal Police Force and ONDCP) participated in the 61st CFATF Plenary, reaffirming commitment to financial integrity and preparation for the Fifth Round Mutual Evaluation. 28 Nov 2025

Sanctions changes

  • Recurrent OFAC SDN listings throughout the window targeted Antigua and Barbuda-flagged vessels (tankers, bulk carriers, container ships) and, separately, Antigua-incorporated shipping/holding entities, for Iran and Russia oil-sanctions evasion. 10 Apr 2025
  • The EU updated its list of high-risk third countries (Delegated Regulations (EU) 2026/46 and 2026/83, effective 29 Jan 2026), adding Bolivia, the British Virgin Islands and Russia; Antigua and Barbuda was not added, consistent with its continued absence from the FATF grey/black lists. 29 Jan 2026
  • US imposition of a travel-ban designation on Antigua and Barbuda (effective Jan 2026) functions as a restrictive measure distinct from OFAC financial sanctions, targeting the jurisdiction's CBI programme rather than specific designated persons or entities. 16 Dec 2025

Regulatory horizon (register)

  • CFATF Fifth Round Mutual Evaluation of Antigua and Barbuda
  • Eastern Caribbean CBI Regulatory Authority becomes operational
  • Publication of Antigua and Barbuda's updated National Risk Assessment
  • Next EU high-risk third-country list update

Active schemes

  • [HIGH] Flag-of-convenience shadow-fleet exploitation
  • [HIGH] Citizenship-by-Investment identity-concealment vehicle
  • Drug-trafficking cash/MSB layering hub
Sources
  1. CFATF / FATF
  2. Office of National Drug and Money Laundering Control Policy (ONDCP), Government of Antigua and Barbuda
  3. ONDCP, Government of Antigua and Barbuda
  4. CFATF / FATF
  5. US Department of the Treasury, Office of Foreign Assets Control
  6. OCCRP
  7. European Commission
  8. ONDCP, Government of Antigua and Barbuda
Coverage gaps
Antigua and Barbuda's first National Risk Assessment, comple…
Antigua and Barbuda's first National Risk Assessment, completed in Q2 2017, was never published; the CFATF Mutual Evaluation Report (2018) and 2021 Follow-Up Report remain the only public reference documents for structural AML/CFT risk until the Jan 2025 NRA update exercise reports out.
The Citizenship by Investment Programme lacks a formal requi…
The Citizenship by Investment Programme lacks a formal requirement to conduct ML/TF risk assessments, has limited audit functions, and lacked documented policy at the time of the 2018 MER; supervision sits primarily with private CIP agents rather than a fully independent statutory authority.
Targeted financial sanctions related to proliferation financ…
Targeted financial sanctions related to proliferation financing (R.7) remain rated only Partially Compliant after the 2021 Follow-Up Report; there is no clear guidance to financial institutions and DNFBPs holding targeted funds on their freezing obligations, and no ability to freeze without prior notice.
Non-profit organisation sector oversight remains rated Non-C…
Non-profit organisation sector oversight remains rated Non-Compliant (R.8); the country has been unable to identify whether NPOs posing TF risk exist and has not implemented measures to mitigate that risk, despite TF being assessed as low overall.
Despite repeated OFAC designations of Antigua and Barbuda-fl…
Despite repeated OFAC designations of Antigua and Barbuda-flagged vessels (Apr 2025, Aug 2025, Jul 2026) for Iran and Russia oil sanctions evasion, there is no public evidence of Antigua and Barbuda's flag registry independently deregistering or sanctioning the vessels/owners involved, relying instead on the designating state's action.

Evidence

Confidence-tiered claims

Compliant or largely compliant with 36 of 40 FATF Recommendations per most recent CFATF follow-up Mutual Evaluation Report (Nov 2021, on the Oct 2018 on-site MER). SRC-fim-AG-003
Probable · 1 source
National Risk Assessment launched in 2025 remains in progress as of the IMF's February 2026 Article IV mission. SRC-fim-AG-004
Probable · 1 source
Antigua-registered entity listed on OFAC SDN list under Russia-related authorities, January 2025; no update this cycle. SRC-fim-GLOBAL-001
Confirmed · 1 source
No international sanctions regime currently reported in force against Antigua and Barbuda itself. SRC-fim-AG-006
Uncertain · 1 source
Now subject to a newly enacted independent regional CIP regulator shared with other ECCU CIP states, per the IMF mission statement. SRC-fim-AG-004
Probable · 1 source