Key Takeaways
- Anguilla appeared on the EU's Annex I and Annex II lists during 2020-2021, primarily over economic substance and information-exchange shortfalls.
- Commitments and reforms enabled delisting, and the jurisdiction has not featured on the FATF grey or black lists.
- Beyond the EU and FATF, OECD and Global Forum transparency ratings and various national lists are worth checking before incorporating.
- Listing history can still affect banking, due diligence, and counterparty perception even after a jurisdiction is removed.
Anguilla on the Global Watchlists: What "Grey" and "Black" Really Mean Here
If you are weighing whether to incorporate in Anguilla, the grey/black list question matters because the territory sits on the EU blacklist of non-cooperative tax jurisdictions. That status is set by the Council of the European Union through its official EU list, and it shapes how EU-regulated banks, counterparties, and tax authorities treat an Anguilla-incorporated entity.
Two separate listing systems are usually confused under the words "grey" and "black". One is the EU tax list, run by the Code of Conduct Group; the other is the FATF list, which addresses anti-money laundering and is wholly distinct.
This article sets out where the firm stands on each, why it was listed, what reforms have been attempted, and what listing means for a foreign owner in practice. It is most relevant to non-resident investors and their advisers comparing offshore options or maintaining an existing structure.
The EU Lists Explained: Annex I (Blacklist) and Annex II (Greylist) Status for Anguilla
The EU list of non-cooperative tax jurisdictions is a tool Member States use to address external risks of tax abuse and unfair competition. It has two parts: Annex I, the blacklist, names jurisdictions assessed as non-cooperative; Annex II, the so-called greylist, records jurisdictions that fall short of the standards but have given credible commitments to reform.
Three families of criteria drive the assessment: tax transparency, fair taxation, and implementation of the OECD's BEPS minimum standards. The Code of Conduct Group for Business Taxation manages the screening, and the European Commission monitors progress.
Established in December 2017, the list is revised twice a year. Where the territory falls is straightforward.
| Item | Detail |
|---|---|
| Current annex | Annex I (blacklist) |
| Confirmed at | 17 February 2026 revision |
| Grounds | Criterion 1.2 (information exchange) and criterion 2.2 (economic substance) |
| Total jurisdictions on Annex I | Ten |
The blacklist names ten jurisdictions after the February 2026 revision: American Samoa, Anguilla, Guam, Palau, Panama, Russia, the Turks and Caicos Islands, the US Virgin Islands, Vanuatu, and Vietnam.
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Anguilla's 2020-2021 EU Greylisting and Blacklisting: The Full Timeline
The relationship with the EU list runs back to the first screening round, and it has moved between annexes more than once. The sequence below tracks each decision.
- 2017: Screening was paused for eight Caribbean jurisdictions struck by the September 2017 hurricanes, deferring the territory's review.
- 2018-2019: Placed on Annex II after committing to compliance by the end of 2019.
- 12 March 2019: Avoided a first blacklisting; substance concerns under criterion 2.2 were treated as addressed, while the information-exchange rating remained under review.
- 6 October 2020: Added to Annex I after the OECD Global Forum downgraded its tax-transparency rating.
- 5 October 2021: Removed from Annex I and moved back to Annex II, pending a supplementary Global Forum review, alongside Dominica and Seychelles.
- 4 October 2022: Re-added to Annex I, together with The Bahamas and the Turks and Caicos Islands.
- October 2023: Formally listed under criterion 1.2 after a "Partially Compliant" rating in the supplementary EOIR review, and remained listed under criterion 2.2.
- February 2025, October 2025, February 2026: Status maintained at each update.
The 2022 re-listing rested on a finding that a zero or nominal corporate tax setting was drawing in profits without meaningful local activity, and that recommendations from the OECD Forum on Harmful Tax Practices on enforcing substance had not been met.
The Specific Concerns Cited: Economic Substance and Information Exchange Shortfalls
The Council's reasoning, as recorded in its 2024 conclusions, is twofold. The territory does not hold a rating of at least "Largely Compliant" for exchange of information on request (criterion 1.2), and it is assessed as facilitating offshore structures that attract profits without real economic substance (criterion 2.2).
On information exchange, the 2020 peer review found practical failures: accounting records were not reliably available, and requests from partner jurisdictions went unanswered. Part of that breakdown was traced to organisational problems and the closure of service providers after the 2016 data leaks involving a local law firm and corporate service provider.
A 2023 supplementary review recorded improvement to "Partially Compliant", reflecting steps taken against the earlier recommendations. Implementation gaps in organisational processes persisted, however, producing less-than-effective exchange in practice.
The substance objection is narrower in wording but persistent in effect. ECOFIN states that the jurisdiction fails to take all necessary actions to ensure effective implementation of substance requirements, a concern first flagged in the 2016 EU screening. Membership of the BEPS Inclusive Framework, joined in 2018, has not resolved it.
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The Commitments and Reforms Anguilla Made to Secure Delisting
Substance rules were legislated in January 2019 through amendments to the Companies, International Business Companies, Limited Liability Companies, and Limited Partnerships statutes, each paired with Economic Substance Regulations and Rules. The provisions applied from 1 January 2019 to entities registered on or after that date, and from 1 July 2019 to existing entities.
Under that framework, an entity carrying on a relevant activity must either qualify for exemption or pass the substance test. Exemption is available where the entity is managed and controlled, or carries out the activity, in a jurisdiction with a corporate tax rate of at least 10% and is tax resident there.
Non-exempt entities must conduct core income-generating activities locally, maintain adequate physical presence, employ suitably qualified staff, incur operating expenditure, and file an economic substance return with the Registrar. Pure holding companies face a lighter version of the test.
The October 2021 move off Annex I was secured on the strength of these reforms and good-governance commitments. The October 2022 re-listing followed an assessment that enforcement of the substance rules, not their existence, fell short of FHTP recommendations.
One reform area singled out was widening spontaneous exchange of information beyond EU Member States to all relevant partner jurisdictions. On the transparency side, financial institutions file CRS data through the Anguilla AEOI Portal, and the International Tax Cooperation Department issued a newsletter in April 2025 describing amendments made on 26 July 2024 to the International Tax Compliance (CRS) Regulations, 2016.
FATF Standing: Why Anguilla Has Not Featured on the Grey or Black Lists
The FATF maintains two AML/CFT documents, issued three times a year, popularly called the black and grey lists. Anguilla appears on neither.
The FATF blacklist names only three countries: North Korea, Iran, and Myanmar. The June 2025 grey list runs to more than twenty jurisdictions, but the territory is not among them as a standalone entry.
One point of confusion is worth clearing up. "Virgin Islands (UK)" on the FATF grey list refers to the British Virgin Islands, a separate British Overseas Territory.
As a member of the Caribbean Financial Action Task Force, the regional FATF-style body, the jurisdiction underwent a mutual evaluation adopted by the CFATF Council of Ministers in July 2010. A more recent CFATF assessment is reflected in a document on the FATF country page dated 7 March 2025; confirm the specific ratings there directly. The EU blacklisting is a tax-governance matter, not an AML/CFT finding.
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OECD and Forum Assessments: Anguilla's Position on Transparency Ratings
Membership of the OECD Global Forum brings periodic peer review of how the territory exchanges information. The September 2020 second-round review produced a "Non-Compliant" rating, the trigger for the first blacklisting.
A 2023 supplementary report, published in July, lifted the rating to "Partially Compliant". That label means the standard is only partly implemented, with at least one material deficiency that has had, or is likely to have, a significant effect on exchange in practice.
The EU floor is "Largely Compliant", so a "Partially Compliant" outcome keeps the firm in breach of criterion 1.2. Separately, the automatic-exchange framework operates under the International Tax Compliance (CRS) Regulations, 2016, with an annual FATCA and CRS reporting deadline of 31 May for the preceding period.
Economic substance enforcement remains under FHTP review, the unresolved criterion 2.2 finding. A verified Global Forum AEOI peer review rating was not located in the source material; check the OECD Global Forum ratings portal for the current position.
Other National and Supranational Lists Worth Checking Before You Incorporate
EU listing is not the only register that touches an Anguilla structure. Several follow-on consequences attach to Annex I status.
- EU defensive measures: Member States must apply at least one measure to residents dealing with listed jurisdictions, a requirement in force since 2021. These include enhanced transaction monitoring, controlled foreign company rules, non-deductibility of costs, withholding tax, and loss of the dividend participation exemption.
- EU funds: Investments drawing on certain EU funds, such as the European Fund for Strategic Investments, may be barred for residents of listed countries.
- Securitisation: Under EU Regulation 2021/557, securitisation special purpose entities should not be set up in an Annex I jurisdiction.
- Member State national lists: France, Portugal, Spain, Germany and others keep their own blacklists, which can diverge from the EU list; verified data on which include the territory was not retrieved, so check the client's home-country list separately.
- UK: As a British Overseas Territory, the jurisdiction is under UK oversight but not treated like a third-party tax haven; confirm the position through HMRC guidance.
- FATCA and CRS: FATCA reporting runs through the local Inland Revenue Department, and CRS data is shared only with partners meeting confidentiality standards. Confirm the FATCA IGA status on the US Treasury tracker and the current CRS partner list via the AEOI portal.
Practical Consequences for Non-Resident Owners: Banking, Due Diligence, and Perception
Persistent Annex I status changes how the wider financial system treats your entity, though the exact effect depends on where you and your counterparties sit. The headline issue is friction, not prohibition.
EU-regulated banks, and non-EU banks applying EU-equivalent standards, will generally treat an Anguilla company as higher risk and run enhanced due diligence at onboarding. Account opening takes longer and asks more of you, particularly on beneficial ownership and source of funds.
The defensive measures noted above flow through to the owner's home country and to the Member States the structure transacts with. A foreign owner may encounter CFC attribution, non-deductible payments, or withholding, depending on the specific national rules in play.
Reporting obligations run in parallel. Financial institutions meet the 31 May FATCA and CRS deadline, and a non-resident account holder's details are reported automatically to their home tax authority.
Any entity carrying on a relevant activity must pass the economic substance test and file an annual return with the Registrar. Non-compliance raises both regulatory and reputational exposure on top of the listing itself.
Reputation is the quieter cost. Continuous presence on Annex I since October 2022 is a factor that fund administrators, professional firms, and correspondent banks weigh in risk-based assessments, even where AML concerns, the FATF question, are absent.
Current Status Snapshot and Forward Outlook for Anguilla
The position can be stated plainly: after the 17 February 2026 revision, the territory remains on the EU blacklist among ten listed jurisdictions. Both grounds for listing are unresolved.
Two things must change for delisting. The OECD Global Forum would need to lift the EOIR rating to at least "Largely Compliant" in a future review, and the FHTP would need to be satisfied on enforcement of economic substance. Neither had occurred by the February 2026 update.
Progress exists but has stalled. The 2023 upgrade from "Non-Compliant" to "Partially Compliant" shows movement, yet re-listing in 2022 and maintenance since suggest the reform pace has lagged EU and OECD timelines.
The list is revised twice yearly, so the next scheduled update falls around mid-2026. The FATF position offers the contrasting reassurance, with no grey or black listing in play.
- Verify the EU status at each update cycle and watch Council press releases.
- Check which defensive measures the client's home jurisdiction applies.
- Run enhanced due diligence ahead of any EU-regulated banking relationship.
Conclusion
Anguilla sits on the EU blacklist on two unresolved grounds, information exchange and economic substance, while staying clear of the FATF grey and black lists, which keeps this a tax-governance issue rather than an AML one. For a foreign owner, that means workable but heavier banking due diligence, possible defensive measures in the home country, and mandatory substance filings for any active company. The practical decision turns on your purpose for the entity and the jurisdictions it will deal with. Track the status at each Council update, since the listing can shift in either direction.
How Expanship Can Help Your Business in Anguilla
Expanship advises foreign owners on what the EU listing means for a specific structure, helps active companies meet economic substance and reporting obligations, and prepares for the enhanced due diligence that banks apply to listed-jurisdiction entities. That sits within a fuller set of services for running a foreign-owned company in the territory.
- Company formation and entity structuring
- Registered agent and registered office
- Tax registration and annual filing
- Economic substance and ongoing compliance management
- Accounting and bookkeeping
- Introductions to banking partners
To discuss your structure and next steps, contact Expanship Anguilla.
Frequently Asked Questions
Yes. Following the 17 February 2026 revision, Anguilla is one of ten jurisdictions on Annex I of the EU list of non-cooperative tax jurisdictions. It has remained there continuously since October 2022.
Two grounds apply. It does not hold at least a "Largely Compliant" rating from the OECD Global Forum for exchange of information on request (criterion 1.2), and it is assessed as facilitating offshore structures that attract profits without real economic substance through insufficient enforcement of its substance rules (criterion 2.2).
No. Anguilla does not appear on either FATF list as a standalone territory; the FATF blacklist names only North Korea, Iran, and Myanmar. The "Virgin Islands (UK)" entry on the grey list refers to the British Virgin Islands, a different territory.
EU Member States must apply at least one defensive measure to dealings with listed jurisdictions, which can include CFC rules, withholding tax, or non-deductible costs depending on the country. In practice you should also expect enhanced due diligence and longer onboarding at EU-regulated banks.
Delisting requires an OECD Global Forum upgrade to at least "Largely Compliant" on information exchange, plus a satisfactory FHTP assessment of economic substance enforcement. Neither condition had been met by the February 2026 update.
If it carries on a relevant activity and does not qualify for exemption, yes; it must pass the substance test and file an annual return with the Registrar. A company managed in a jurisdiction with a corporate tax rate of at least 10% where it is tax resident may be exempt, and pure holding companies face a lighter test.
Legal Disclaimer
The information provided in this article is for general informational purposes only and does not constitute legal, tax, or professional advice. While we strive to ensure the accuracy and timeliness of the content, laws and regulations are subject to change, and the application of laws can vary widely based on specific facts and circumstances.
Readers should not act upon this information without seeking professional counsel tailored to their individual situation. Expanship and its authors disclaim any liability for actions taken or not taken based on the content of this article.
For specific advice regarding your business setup, compliance requirements, or any legal matters, please consult with qualified legal and tax professionals in the relevant jurisdiction.
