Financial Integrity Monitor
Vanuatu VU
Sources
7
Jurisdiction profile
CompliantTier CRisk: IncreasingMixed
Vanuatu's AML/CFT regime rests on the Anti-Money Laundering and Counter-Terrorism Financing Act No.13 of 2014 (as amended), the Counter Terrorism and Transnational Organised Crime Act, the Proceeds of Crime Act, and the Companies/International Companies Acts governing beneficial ownership.
Key deficiencies
- Backlog and quality gaps in beneficial-ownership declarations by International Companies, per EU Commission/OECD Global Forum findings
- Citizenship-by-investment (CBI) programme vetting weaknesses enabling access by sanctioned, Interpol-listed, and criminally investigated individuals
- 2024 NRA finding that Vanuatu is 'high-risk' for proliferation financing, attributed directly to the CBI programme
- Chronic capacity constraints at VFIU/VFSC/RBV limiting onsite supervision of TCSPs, casinos, and the international (offshore) banking sector
- Persistent EU listing as a high-risk third country since September 2016 despite FATF delisting in 2018, reflecting unresolved BO-transparency concerns
Recent developments (18m)
- 2024 National Risk Assessment finalised and published online (Feb 2026), including Vanuatu's first proliferation-financing risk assessment
- Virtual Asset Service Providers Act passed by Parliament (26 March 2025), establishing Vanuatu's first licensing framework for crypto businesses
- Reserve Bank of Vanuatu revoked Pacific Private Bank's international banking licence (Nov 2025) following an OCCRP investigation into alleged investor-fund siphoning via a crypto-linked ICO
- OFAC designated multiple individuals holding Vanuatu passports/citizenship linked to the Cambodia-based Prince Group transnational criminal organisation (Oct 2025) with further related designations (Jun 2026)
- OFAC designated the Vanuatu-flagged crude oil tanker SEEKER 8 under Iran petroleum sanctions (Apr 2026)
- European Commission's 13th AML high-risk third-country list iteration (Dec 2025, in force 9 Jan 2026) retained Vanuatu, unchanged since 2016
- NCC launched the Mutual Evaluation Technical Team (METT) and published a National AML/CTF/CPF Strategy (Aug 2025) ahead of an expedited APG Mutual Evaluation
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
- Following an OCCRP/15min investigation showing the bank was used by the founders of Lithuanian crypto-finance firm Bankera to allegedly extract investor funds via a crypto ICO, the central bank issued a September 2025 warning letter and then revoked PPB's international banking licence in November 2025. 4 Nov 2025
- OFAC added individuals to the SDN list under its Transnational Criminal Organizations programme, identifying several by Vanuatu passport numbers and, in one case, Vanuatu nationality, as linked to Cambodia-based scam-compound networks including Prince Group. 14 Oct 2025
- A further round of OFAC Transnational Criminal Organizations designations again identified individuals by Vanuatu passport numbers and nationality, alongside Russia-related delistings and publication of an OFAC-OFSI comparative sanctions overview. 23 Jun 2026
- OFAC designated the tanker SEEKER 8, flying the Vanuatu flag (formerly Panama), under Iran petroleum-sanctions authority (EO 13902), as linked to Reayou Company Limited, as part of a broader Iran-related designation action. 24 Apr 2026
Sanctions changes
- The European Commission adopted Delegated Regulations (EU) 2026/46 and (EU) 2026/83 (published 9 Jan 2026, amending Delegated Regulation (EU) 2016/1675), confirming the 13th iteration of the EU high-risk third-country AML/CFT list. Vanuatu remains listed, with its original 23 September 2016 entry-into-force date unchanged. 9 Jan 2026
- OFAC's October 2025 Transnational Criminal Organizations designation round added individuals to the SDN list identified in part by Vanuatu passport numbers and, in at least one case, Vanuatu nationality, linked to the Cambodia-based Prince Group network. 14 Oct 2025
- OFAC designated the Vanuatu-flagged tanker SEEKER 8 under Iran petroleum-sector sanctions authority (EO 13902), alongside other vessels and entities in an Iran-related designation update. 24 Apr 2026
- A further June 2026 OFAC Transnational Criminal Organizations designation round again listed individuals identified via Vanuatu passports, published jointly with Russia-related delistings and an OFAC-OFSI comparative sanctions overview. 23 Jun 2026
Regulatory horizon (register)
- APG 5th-round Mutual Evaluation of Vanuatu
- Next EU high-risk third-country list update
- VFSC rollout of VASP Act 2025 licensing regime
- Implementation of 2025 National AML/CTF/CPF Strategy
Active schemes
- [HIGH] CBI golden-passport identity layering for TCO figures
- Offshore international-banking licence abuse
- [HIGH] Flag-registry use in Iran oil sanctions evasion
Sources
- Vanuatu Financial Intelligence Unit (Government of Vanuatu)
- National AML&CTF Coordinating Committee, Government of Vanuatu (hosted by Financial Centre Association of Vanuatu)
- European Commission (DG FISMA)
- Council of the European Union
- U.S. Department of the Treasury, Office of Foreign Assets Control
- Organized Crime and Corruption Reporting Project (OCCRP)
- Financial Action Task Force (FATF)
Coverage gaps
Evidence
Confidence-tiered claims
No structured claims published for this jurisdiction yet.