Belize Grey/Black List: Where It Stands Today

Belize on the Global Watchlists: What Listing Status Means for Foreign OwnersCopy link to section

The grey/black list position of Belize matters because three separate bodies assess the jurisdiction against different standards, and the answers do not always align. Belize sits on the European Union's Annex II greylist of jurisdictions with pending tax cooperation commitments, while remaining off the FATF blacklist and outside the FATF's increased-monitoring list.

For a foreign business owner, that status feeds directly into how banks, EU counterparties, and compliance teams score risk on your structure. The EU Council timeline records each move, and the practical effect ranges from extra paperwork to occasional banking friction.

This article explains where the entity stands across the EU, FATF, and OECD frameworks, how it got there, what reforms drove the changes, and what to watch before you incorporate or open an account. It is most useful to non-resident owners of an International Business Company and their advisers weighing the reputational and banking consequences of a listed jurisdiction.

The EU Lists Explained: Annex I Blacklist and Annex II Greylist Positions for BelizeCopy link to section

The EU maintains two lists of non-cooperative tax jurisdictions, first adopted in Council conclusions of 5 December 2017. Annex I, the blacklist, names countries that have not engaged constructively or failed to deliver promised reforms; Annex II, the greylist, names those that fall short on some criteria but have committed to fix them.

Jurisdictions are tested on tax transparency, fair taxation, and the implementation of standards designed to prevent base erosion and profit shifting. Since 2020, the Council refreshes both annexes twice a year.

Belize moved onto the blacklist on 17 October 2023, when ECOFIN added it to Annex I for breaching criterion 1.2 on exchange of tax information on request. The blacklisting was short-lived.

On 20 February 2024, the Council removed the country from Annex I, but the entity was not fully cleared. Unlike the Bahamas and the Turks and Caicos Islands, which were taken off entirely, it was relocated to the Annex II greylist pending the outcome of an OECD review.

Belize has held that Annex II position through subsequent updates, alongside ten other jurisdictions.

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Belize and the FATF: Grey List History, Action Plans, and Current StandingCopy link to section

On the anti-money-laundering side, the jurisdiction is assessed by the Caribbean Financial Action Task Force (CFATF), the FATF-style regional body for the region. Its history here is older than the EU tax dispute.

A CFATF public statement in November 2013 flagged strategic deficiencies in the country's AML/CFT regime and called on members to apply counter-measures. The damage was measurable: the 2013 grey-listing cost Belize 87% of its correspondent banking relationships.

After a wide revision of its legal framework, the country exited CFATF monitoring in May 2015. Its 4th Round Mutual Evaluation followed in 2025, with stronger results.

• Compliant on 38 of the FATF 40 Recommendations
• Largely Compliant on the remaining 2
• Substantially Effective on 5 of the 11 Effectiveness Immediate Outcomes

The firm has never appeared on the FATF blacklist proper, and no international sanctions are in force against it. It does not feature in the FATF's June 2026 increased-monitoring publication, which lists 22 countries; its AML/CFT track is handled at the CFATF level rather than by FATF directly.

The OECD Angle: Harmful Tax Practices Reviews and Belize's Cooperative StatusCopy link to section

The trigger for the 2023 EU blacklisting was an OECD assessment, not a money-laundering finding. The OECD Global Forum gave the country a negative rating on exchange of information on request (EOIR), which fed straight into criterion 1.2.

Belize joined the OECD Inclusive Framework on BEPS and committed to the Action 5 minimum standard on harmful tax practices. The EU offered a route out: secure approval from the Global Forum to open a supplementary EOIR review, and the blacklisting would be reversed.

The country requested that review in December 2023 on the basis of new legislation and administrative changes. On 2 February 2024, the Global Forum approved the request, with the review cycle set to run from early 2025 and the second-round in-depth report published in 2026.

On automatic exchange, the jurisdiction signed the Multilateral Competent Authority Agreement in October 2015 and adopted the Common Reporting Standard, administered through the Financial Services Commission. It holds a "Largely Compliant" Global Forum rating, and has never appeared on the OECD's own list of uncooperative tax havens, which has carried no entries since May 2009.

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Timeline of Belize Listings and Delistings Across All BodiesCopy link to section

The sequence below shows how the entity has moved across bodies, which helps explain why due diligence systems may still flag historical appearances.

Specific Deficiencies Cited and the Reforms Belize Committed ToCopy link to section

The headline failing was narrow: an unfavourable Global Forum assessment of exchange of information on request, captured as criterion 1.2. Older criticisms ran deeper, covering blanket tax exemptions, absent information-exchange agreements, anonymous ownership, and a zero local-activity model.

The IMF's 2023 Article IV review added that AML/CFT supervision of trusts and company service providers needed more work. Several oversight offices, including the Integrity Commission and the Auditor General's Office, sat vacant or under-resourced through much of 2022.

The legislative response was substantial:

• Amendments to the Money Laundering and Terrorism (Prevention) Act, Chapter 104, which gives supervisory powers to bodies including the Central Bank of Belize
• Changes to the Accounting Records Act ahead of the 4th Round CFATF evaluation
• Economic substance requirements, beneficial ownership registers, and automatic information sharing introduced since 2019
• New provisions allowing the central bank to communicate with foreign regulators

Enforcement followed the law. In November 2023 and February 2024, 1,612 companies that failed to meet re-registration requirements under the new Companies Act were struck from the Belize Companies and Corporate Affairs Registry and published in the Gazette.

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Practical Consequences: Enhanced Due Diligence and Correspondent Banking FrictionCopy link to section

Listing status shows up first in banking. The 2013 grey-listing remains the clearest example of cost, with that 87% loss of correspondent relationships, and efforts to rebuild those connections were still in progress at the 2023 IMF mission.

A blacklisting carries sharper consequences than a greylisting. While Belize sat on Annex I, EU member states could apply defensive measures against entities based there: increased withholding tax on dividends and interest, non-deductibility of costs, controlled-foreign-company rules, and limits on participation exemptions.

Blacklist status also pulled in mandatory reporting. Under DAC6 Hallmark C1b(ii), payments to an Annex I entity could trigger a reporting obligation regardless of any tax-benefit motive.

The greylist is lighter but not free of friction. Financial institutions, designated non-financial businesses, and virtual asset service providers use listing status as an input to country risk scoring, and a thinner correspondent network than larger offshore centres means local accounts can face transfer delays or counterparty rejections.

One further trigger affects group structures: jurisdictions held on the greylist for at least two years become subject to enhanced EU Public Country-by-Country Reporting.

How Listing Status Shapes Investor Perception and Reputational RiskCopy link to section

Perception lags reality in compliance systems. The country is no longer the simple tax haven of a decade ago, yet due diligence tools that index historical appearances will still surface the four-month Annex I episode between 17 October 2023 and 20 February 2024.

That short duration limits, but does not erase, lasting reputational drag. The government rejected the original blacklisting as a "false and unfair designation," citing its transparency commitments and exchange-of-information regime.

Treatment is not uniform. EU member states apply their own local lists, defensive measures, and timelines, so a Belize-incorporated entity can meet inconsistent handling across the bloc even while greylisted.

A common adviser response is to separate the place of incorporation from the place of banking. Reported banking for Belize IBCs splits across EU electronic money institutions, Hong Kong and Singapore providers, and domestic banks.

One DAC6 burden has eased: arrangements implemented with the jurisdiction on or after 26 February 2024 are no longer reportable under Hallmark C1b(ii), because the entity left Annex I.

Reading the Current Picture: Where Belize Stands Today and WhyCopy link to section

The status across bodies divides cleanly. On tax, the jurisdiction is greylisted by the EU; on AML/CFT, it is neither blacklisted nor under FATF increased monitoring.

The reason for the remaining greylist position is procedural. The 2023 blacklisting came from a weak EOIR assessment; reforms prompted the OECD supplementary review, and until that review concludes, the entity stays on Annex II.

Greylist status warrants close attention, because a jurisdiction that misses agreed timelines can be returned to the blacklist.

Outlook: What to Watch Before Incorporating or Banking in BelizeCopy link to section

Several decisions ahead will shape whether the entity stays on Annex II or clears it.

• OECD Global Forum review: The Second Round In-depth EOIR review was published in 2026. An upgrade toward "Compliant" would let the EU Code of Conduct Group consider full delisting.
• EU list revision: The list is updated twice yearly, with the revision after October 2025 expected in February 2026, and the Annex II position re-evaluated at each cycle.
• EU Public CbCR threshold: Two years on the greylist triggers enhanced public reporting. Having entered Annex II in February 2024, the jurisdiction reaches that mark in February 2026, a point that matters for owners with EU-linked group structures.
• FATF plenary watch: Plenaries fall in February, June, and October. With 5 of 11 effectiveness outcomes rated Substantially Effective and none Highly Effective, stalled remediation could draw CFATF follow-up.
• Correspondent banking: Rebuilding correspondent relationships is ongoing, and the 2013 loss has not been fully reversed, which remains a real banking risk for IBC owners.
• Enforcement, not just statute: The IMF's 2024 Article IV review named strengthening the AML/CFT framework as a priority, signalling that implementation gaps persist.

ConclusionCopy link to section

The position is mixed rather than alarming: greylisted by the EU on a single procedural criterion, clear of the FATF blacklist, and rated Largely Compliant by the OECD Global Forum. For a foreign owner, the practical consequences are administrative friction and banking caution rather than sanctions or prohibitions. Watch the OECD review outcome and the February 2026 EU revision, since both can move the entity toward full delisting or, if commitments slip, back toward the blacklist. Building a structure with banking arranged outside the place of incorporation, and keeping compliance current, addresses most of the residual risk.

How Expanship Can Help Your Business in BelizeCopy link to section

Expanship helps foreign owners read their exposure to the EU greylist and the AML/CFT regime, structure entities to limit due-diligence friction, and keep filings aligned with the standards driving each review. Beyond listing matters, we support the full lifecycle of a non-resident-owned company.

• Company formation and re-registration under the current Companies Act
• Registered agent and registered office services
• Tax registration and the preparation of required returns
• Ongoing compliance management, including economic substance and beneficial ownership obligations
• Accounting and bookkeeping aligned to record-keeping rules
• Introductions to banking and electronic money institutions

To discuss your structure and obligations, contact Expanship Belize.

Frequently Asked QuestionsCopy link to section